In the 1994 case of Arizona v. Isaac Evans, the U.S Supreme Court was asked to consider whether a police officer's failure to inform an arrested individual of his Miranda rights prior to asking questions about a concealed weapon constituted a violation of that individual's Fifth Amendment rights. The court ruled in favor of Arizona, stating that public safety concerns justified the officer’s immediate questioning without first reading Evans his Miranda rights. This decision expanded upon the "public safety exception" established by New York v. Quarles (1984), which allows law enforcement officers to ask limited questions related to public safety before advising suspects of their right against self-incrimination and right for legal counsel under certain circumstances.

The dissenting opinion in the case of Arizona v. Isaac Evans argued that the majority's decision to uphold Evans' conviction despite evidence of prosecutorial misconduct was a departure from established legal principles and undermined defendants' rights to due process. The dissenters contended that the prosecutor's failure to disclose exculpatory evidence, as required by Brady v. Maryland, constituted a violation of Evans' constitutional rights which should have resulted in his conviction being overturned. They also disagreed with the majority's conclusion that this misconduct did not materially affect the outcome of the trial, arguing instead that it had potentially significant implications for both its conduct and result. Furthermore, they expressed concern about setting a dangerous precedent where prosecutors could withhold crucial information without facing any consequences or sanctions.