New York v Quarles (1984) | Definition

Doc's CJ Glossary by Adam J. McKee
Course: Introduction / Policing / Procedural Law

New York v. Quarles (1984) is a landmark SCOTUS decision in which the Court established a public safety exception to the Miranda warnings.

To truly understand the significance of New York v. Quarles, it’s necessary to look at the events leading up to this important 1984 Supreme Court decision. The case began when a woman reported being raped and said that the suspect had a gun. Police officers spotted a man, Benjamin Quarles, matching the description given by the victim. They pursued and apprehended him inside a grocery store.

During the arrest, one of the officers noticed that Quarles was wearing an empty shoulder holster. Concerned about where the gun might be, the officer asked Quarles where the gun was before reading him his Miranda rights. Quarles indicated where he had hidden the gun, and only afterward was he read his Miranda rights.

The Supreme Court’s Ruling

The key issue in New York v. Quarles was whether the gun should be admissible as evidence, considering that Quarles was not read his Miranda rights before being questioned about it. The Supreme Court ruled that it was admissible, creating what’s now known as the public safety exception to the Miranda rule.

In other words, the Court decided that if there is an immediate threat to public safety, law enforcement officers can ask questions to address that threat before reading a suspect their Miranda rights.

Impact of New York v. Quarles

The ruling in New York v. Quarles has had a significant effect on law enforcement procedures. It provided law enforcement with a necessary tool to ensure public safety in potentially dangerous situations. Now, if there’s an immediate danger, officers can ask critical questions to neutralize the threat before providing a Miranda warning.

Criticisms and Support

The decision in New York v. Quarles has been both praised and criticized. Supporters believe that the ruling sensibly prioritizes public safety over procedural formalities. They argue that in some situations, the safety of others must come before the rights of the suspect.

However, critics argue that the decision could potentially be misused to circumvent the Miranda rule. They worry that it may allow law enforcement to question suspects without a Miranda warning under the pretext of public safety.


All in all, New York v. Quarles is a critical case in the world of criminal justice. It’s an excellent example of how the Supreme Court interprets the Constitution to address modern law enforcement challenges. This case has left a significant impact on how police operate and provides a critical exception to the Miranda rule when public safety is at risk.

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Last Modified: 04/13/2023


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