The Burger Court never overruled Miranda, the famous 1966 Warren Court decision that established that the police must provide suspects with warnings—called Miranda warnings—before interrogating them. Under the Miranda decision, prosecutors cannot use incriminating statements given by criminal defendants when they were not told of their right not to incriminate themselves and right to have an attorney present during questioning. The Court issued the decision partly because of the problem of coerced confessions. However, the Burger Court created exceptions to it in several decisions. In Harris v. New York (1971), the Court ruled that prosecutors can impeach defendants at trial with statements they previously made without receiving their Miranda warnings. The Court ruled that the Miranda decision should not be read as sanctioning perjury. In Quarles v. New York (1984), the Court created a public-safety exception to Miranda when police officers do not have time to deliver Miranda warnings. Then, in Oregon v. Elstad (1985), the Court ruled that an initial failure to deliver Miranda warnings does not prevent the use of confessions and admissions made after Miranda warnings have been given.