Monday, November 4, 2013

New York v. Quarles case brief

New York v. Quarles case brief summary
467 U.S. 649 (1984)

CASE SYNOPSIS
In respondent suspect's prosecution for criminal possession of a weapon, petitioner State sought review of a decision of the Court of Appeals of New York, which affirmed the trial court's suppression of respondent's statement, "the gun is over there," and the gun on the ground that the statement was made by police before they read respondent his Miranda rights.

CASE FACTS
A police officer pursued respondent suspect in a supermarket after a woman identified him as the man who raped her. The officer frisked respondent and discovered that he was wearing an empty shoulder holster. After handcuffing respondent, the officer asked him where the gun was. Respondent said, "the gun is over there." After the officer retrieved the loaded gun, he placed respondent under arrest and read him his Miranda rights. In the subsequent prosecution of respondent for criminal possession of a weapon, the judge excluded the statement and the gun because the officer had not given respondent his Miranda warnings before asking him where the gun was located. The state appellate courts affirmed, rejecting petitioner State's argument that the exigencies of the situation justified the officer's failure to read respondent his Miranda rights until after he had located the gun.

DISCUSSION
  • The Court reversed. 
  • The Court held that there was a "public safety" exception to the requirement that Miranda warnings be given before a suspect's answers could be admitted into evidence, and that the availability of that exception did not depend upon the motivation of the individual officers involved.

CONCLUSION
The Court reversed the decision of the state court. The Court held that under the facts of the case there was a public safety exception to the requirement that Miranda warnings be given before a suspect's answers could be admitted into evidence.



Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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