Nix v. Williams 467 U.S. 431 (1984)

U.S. Supreme Court
Nix v. Williams, 467 U.S. 431 (1984)
Nix v. Williams
No. 82-1651
Argued January 18, 1984
Decided June 11, 1984
467 U.S. 431

Robert Allen Williams was arrested for the murder of 10 year old Pamela Powers which occurred on December 24 1968. Williams disposed of the body on a gravel road in Mitchellville Iowa. Law enforcement from the state of Iowa and over 200 volunteers conducted a search in the area of Mitchellville due to finding articles of clothing nearby. On the ride from Davenport to Des Moines Williams made statements to the police without an attorney present due to conversation that was initiated by officers. The statements made led them to find the child lying in a culvert. After the child was found he was arrested and read his Miranda rights. It was found that the statements given by Williams were obtained unlawfully and were not allowed to be presented during the trial, however photos, medical and chemical evidence was allowed. It was argued in court that even if Williams had not made the statements that led to the discovery the child would have been found due to the search of the volunteers with evidence that could still be used to convict.
Procedural History
First trial
Williams was indicted for the murder of Pamela Powers in 1969. In the first trial the defense argued that the police interrogated Williams on the ride from Davenport to Des Moines hoping to get information about the girl. Williams had at that time retained counsel and the defense moved to suppress the statements due to unlawful interrogation and to the defendant?s right to counsel. The prosecution argued that the discovery was inevitable due to the search pattern and location of the volunteers. The motion for the defense was denied and Williams was found guilty of first degree murder in 1970. Williams appealed his conviction and it was affirmed however, the second appeal to the Iowa Court of Appeals was reversed. Williams? attorneys filed for Habeas Corpus and it was granted. The courts affirmed and Certiorari was granted.
Second trial
In 1977 Williams second trial commenced, however, the prosecution did not offer the statements made by Williams to the police. Prosecutors offered into evidence the body of the girl as if the defendant never made the statements. Williams was again found guilty of first degree murder. The Iowa Supreme Court affirmed the conviction stating that the police did not act in bad faith when they questioned Williams on the ride. The high court also found that the body would have been inevitably found during the search. The lower court?s decision was reversed based on the fact that they had not proven the police were acting in bad faith. In 1983 Habeas Corpus and Certiorari were again granted.
Legal Issues
The legal issue here is whether the evidence that resulted in the arrest should be excluded from trial due to the improper and unlawful interrogation of police officers.
Did the comments of the officers as to the ?Christian burial? in effect cause and unlawful interrogation and did that violate the defendant?s right to counsel. Is there an inevitable discovery exception to the exclusionary rule?
Decision of the Court
Held. The fact that the body and or evidence would have been discovered within a short time period of the search by volunteers the doctrine of inevitable discovery applies. The method of which the evidence was discovered becomes irrelevant and is still allowed against the defendant.
Dissent. Justice Brennan dissented, inevitable discovery relies heavily on a hypothetical scenario that may or may not produce the evidence. Therefore since the evidence was not discovered by legal means it remains unconstitutionally obtained.
Concurrence. Justices Stevens and White Concurred, maintaining the same holding.
Legal Analysis
In Nix v. Williams the United States Supreme Court upheld William?s conviction due to the inevitable discovery doctrine. In this instance, the exclusionary rule -the termination of evidence due to the fraudulent nature of which it was obtained-did not apply to this case due to the fact that the child?s body was entered in and viewed as evidence. It was also found that the body and or evidence would have been found even if Williams would not have offered the statements to the officers. In the United States the doctrine of inevitable discovery is found in criminal procedure and