Facts
- A woman told two New York City police officers she had just been raped, described the assailant, said he had a gun, and reported he entered a nearby supermarket.
- An officer entered the supermarket, saw Benjamin Quarles matching the description, pursued him, and briefly lost sight of him.
- The officer stopped Quarles, frisked him, and found an empty shoulder holster.
- Without giving Miranda warnings, the officer handcuffed Quarles and asked, “Where’s the gun?”
- Quarles indicated the gun’s location among cartons; the officer recovered a loaded revolver.
- The officer then arrested Quarles, administered Miranda warnings, and Quarles made additional statements about owning and purchasing the gun.
- Quarles was charged with criminal possession of a weapon.
Issues
- Whether Miranda requires suppression of an unwarned custodial response to an officer’s question about the location of a missing gun when the question is prompted by an immediate safety concern.
- Whether the gun recovered as a result of the unwarned answer must also be suppressed.
- Whether any exception to Miranda depends on the officer’s subjective motivation or on an objective safety-based standard.
Decision
- The Supreme Court reversed the suppression orders.
- The Court held that a “public safety” exception permits limited unwarned custodial questioning when questions are objectively prompted by an immediate concern for officer or public safety.
- Quarles’s unwarned statement identifying the gun’s location was admissible under the exception.
- The gun recovered as a result of the unwarned statement was admissible.
- The Court applied an objective test and did not require proof of the officer’s subjective intent.
Legal Principles
- Miranda warnings are generally required before custodial interrogation, but a limited public-safety exception allows unwarned questions aimed at removing an immediate danger.
- The exception applies when questioning is objectively “reasonably prompted” by a concern for public safety, including the risk posed by an unsecured weapon in a public place.
- The exception’s availability does not turn on an officer’s subjective motivation; courts assess the circumstances objectively.
- When the exception applies, both the unwarned response and physical evidence obtained as a direct result may be admitted.
Conclusion
The Court recognized a narrow public-safety exception to Miranda, permitting admission of an unwarned custodial answer and the recovered firearm where an officer’s question about a missing gun was objectively justified by an immediate safety risk in a public setting.