In the 1983 case New York v. Quarles, the U.S. Supreme Court established what is known as the "public safety exception" to the Miranda rule. The case involved a rape suspect, Benjamin Quarles, who was arrested by police in a supermarket after being identified by his victim. Upon arrest, he was found wearing an empty shoulder holster and when asked where his gun was before being read his rights under Miranda v Arizona (1966), he directed officers to its location in a nearby bin of detergent boxes. At trial, this statement and evidence were used against him despite not having been Mirandized prior to questioning about the weapon's whereabouts. The Supreme Court ruled 5-4 that such statements can be admissible due to public safety concerns overriding strict adherence to Miranda procedures - hence creating an exception for situations where immediate interrogation is necessary for public protection or officer safety reasons.

In the dissenting opinion for New York v. Quarles, Justice Thurgood Marshall, joined by Justice William Brennan and Justice John Paul Stevens, argued that the majority's creation of a "public safety" exception to Miranda rights was not justified. They contended that there were already existing legal mechanisms in place to deal with situations where public safety is at risk. The dissenters believed that this new exception could potentially be exploited by law enforcement officers who might use it as an excuse to bypass reading suspects their Miranda rights during arrest or questioning. They also expressed concern about leaving the determination of what constitutes a "public safety" threat up to individual police officers' discretion without any clear guidelines or standards.