In New York v. Quarles, the Supreme Court attempted to limit the exclusionary sanction provided under Miranda v. Arizona. Quarles is a significant decision in the criminal procedure area not only because of the exception which it establishes, but because it represents "a legitimate effort by the Burger Court to reconcile the realities of effective law enforcement with the often hyper technical rules of criminal justice." Many observers have interpreted the Quarles decision as the long-awaited fruition of the conservatism now presiding over the Burger Court. However, the setting for Quarles can be traced back to the Miranda decision itself.
John R. Bode,
New York v. Quarles:The "Public Safety" Exception to Miranda,
U. Rich. L. Rev.
Available at: http://scholarship.richmond.edu/lawreview/vol19/iss1/11