Code of Criminal Procedure · York v. Quarles

York v. Quarles

York v. Quarles is covered under York v. Quarles and tested on the TCOLE peace officer licensing exam. Cadets typically encounter this topic under "Statements" on practice exams.

To prove this offense, the State must establish each of the following elements: Immediate threat to public safety; Questions narrowly tailored to address the threat; Statements admissible as substantive evidence.

Elements you must prove

  • Immediate threat to public safety
  • Questions narrowly tailored to address the threat
  • Statements admissible as substantive evidence

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Worked examples

Worked example 1

Under the public safety exception, officers may ask questions necessary to address an immediate threat to public safety BEFORE giving Miranda warnings. The case is:

  1. Miranda v. Arizona
  2. New York v. Quarles Correct
  3. Edwards v. Arizona
  4. Texas v. Cobb
Why: Quarles held that questions reasonably prompted by an immediate concern for public safety (e.g., 'Where is the gun?') may be asked before Miranda warnings, and the answers are admissible.
Statute: New York v. Quarles, 467 U.S. 649 (1984)