New York v. Quarles

Quarles was in custody for Miranda purposes when the officer asked him where the gun was located. Nonetheless, the Court held that there is an overriding “public safety” exception to the requirement that Miranda warnings be provided before a custodial interrogation. The Court concluded that Miranda warnings are not required when “police officers ask questions reasonably prompted by a concern for public safety.” Here, the officer was “confronted with the immediate necessity of ascertaining the whereabouts of a gun which [he] had every reason to believe the suspect had just removed from his empty holster and discarded in the supermarket.” While the gun remained concealed in the supermarket, it posed numerous dangers to public safety. The officer “needed an answer to his question not simply to make his case against [the defendant], but to insure that further danger to the public did not result from the concealment of the gun in a public area.”