New York v. Quarles

The dissenting justices pointed out that the Miranda rule did not represent a "decision about public safety; it was decision about coerced confessions." They questioned how, given the majority opinion's exception to the Miranda rule, police officers could avoid future misunderstandings when apprehending suspects. Nonetheless, the majority of justices believed their ruling to be an expression of clarification which extended the Miranda rule to allow law enforcement more latitude in instances where there appeared to be a risk to the safety of officers or the public. Thus, the Court ruled that an individual's Fifth Amendment rights could be superseded in specific circumstances. In an apparent departure from years of upholding an explicit, resolute, and persistent interpretation of Miranda, the U.S. Supreme Court made a precedent-setting decision in rationalizing that when security concerns were involved, police offers were justified in delaying Miranda warnings. Justice Rehnquist wrote:

The exception will not be difficult for police to apply because in each case it will be circumscribed by the exigency which justifies it. We think police officers can and will distinguish almost instinctively between questions necessary to secure their own safety or the safety of the public and questions designed solely to elicit testimonial evidence from a suspect.