Nix v. Williams

Petitioner
Crispus Nix
Respondent
Robert Anthony Williams
Petitioner's Claim
That evidence pertaining to the discovery of a body was properly admitted because it would have ultimately been discovered, even if the defendant's rightto counsel had not been violated. Also that the state need not prove the absence of bad faith in securing the evidence.
Chief Lawyer for Petitioner
Brent R. Appel
Chief Lawyer for Respondent
Robert Bartels
Justices for the Court
Warren E. Burger (writing for the Court), Harry A. Blackmun, Sandra Day O'Connor, Lewis F. Powell, Jr., William H. Rehnquist, John Paul Stevens, Byron R.White
Justices Dissenting
William J. Brennan, Jr., Thurgood Marshall
Place
Washington, D.C.
Date of Decision
11 June 1984
Decision
Reversed the court of appeals and held that unlawfully obtained evidence is admissible if it would inevitably have been discovered lawfully. Also held that to establish the admissibility of such evidence, the prosecution does not have to prove the absence of bad faith.
Significance
The ruling settled controversy over whether evidence gained in violation of an arrestee's constitutional rights could still be admissible in court. When that evidence would inevitably have been discovered by lawful means, it wouldbe admissible. This ruling is one example of the Burger Court's broadening ofthe exceptions to the exclusionary rule.
On 24 December 1968 a ten year old girl was abducted from a YMCA in Des Moines and subsequently found dead. Iowa authorities suspected Robert Anthony Williams, who was observed placing what appeared to be a human body wrapped in ablanket into his car the same evening at the YMCA. Williams was arrested at arest stop the next day in Davenport, Iowa. The police found clothes belonging to Pamela Powers, the missing girl, clothing of Williams, and a blanket ata rest stop between Des Moines and Davenport. They presumed that Williams must have hidden the body somewhere between Des Moines and Grinnell, where theyfound clothes and blanket.
State law enforcement officials of Iowa, along with 200 volunteers, began tosearch the area between Grinnell and Des Moines in an effort to recover the body. When Williams surrendered to police in Davenport, the search had been well under way. Williams called an attorney in Des Moines who arranged to havea Davenport attorney escort Williams back to Des Moines with the police. Thelaw enforcement officials to whom Williams surrendered in Davenport agreed not to question Williams on the ride back to Des Moines. This agreement precluded the need for a Davenport attorney to escort Williams back to Des Moines.
On the return trip to Des Moines, however, Detective Leaming broke the agreement and began questioning Williams. Leaming told Williams, in effect, that they would be driving past the general vicinity where the body had been hiddenand, because snow was forecast for that evening, he could save the family andcommunity additional pain and suffering by showing them where the body was.In addition, Leaming told Williams that the least he could do is enable the family to provide a "Christian burial for the little girl who was snatched away from them on Christmas Eve." Williams ultimately agreed to show the policewhere the body was and made self incriminating statements in the process. Thesearch was then called off and the body was recovered. At the time the search was called off one of the search parties was closing in on where the body had been discovered; they were two and one half miles away from the body.
The important aspect of the case, in essence, the reason it was ultimately reviewed by the Supreme Court, centered around the legal ramifications of admitting evidence that has been illegally obtained. In the original trial, Williams had been found guilty by an Iowa state court despite his efforts to have key evidence, the girl's body and the autopsy, suppressed. The defense arguedthat the police learned of the location of the body by the "fruit" of an illegal interrogation. The Iowa state court disagreed, and the Iowa Supreme Courtupheld the decision. Upon being sentenced to life in prison for first degreemurder, Williams took his case to the U.S. District Court for the Southern District on the grounds that he had been unlawfully imprisoned, habeas corpus relief. The district court ruled that the evidence in question, the body of the young girl, should not have been admitted. By a 5-4 margin, the Court of Appeals for the Eighth Circuit upheld the decision.
In Brewer v. Williams (1977) the Supreme Court reviewed the case. TheCourt ruled that, indeed, the Iowa police had violated Williams's Sixth Amendment right to counsel by interrogating him in the car. However, the Court also held that although Williams's self incriminating statements could not be admitted in a second trial, the body "might well be admissible" on the groundsthat it would have ultimately been found in the same condition.
In Williams's second trial in Iowa state court, the prosecution adhered to the U.S. Supreme Court's ruling, and refrained from offering Williams's statements, including his pointing out where the body was, as evidence. The prosecution relied on the location of the body, the autopsy report, and the clothingthat was found to support their arguments. The state court ruled that the body would have inevitably been found by the search party and was therefore admissible as evidence. Williams again was found guilty of first degree murder and sentenced to life in prison. Williams subsequently appealed to the Iowa Supreme Court where it was ruled that the body was admissible on the basis of what is known as the "independent source doctrine." The independent source doctrine simply means that evidence can be allowed if it is discovered independent of a constitutional violation. The Iowa Supreme Court also ruled that the evidence cannot be suppressed on the basis that it had been obtained by the police in "bad faith."
Williams and his defense, however, did not surrender their position. After being denied a writ of habeas corpus in district court in 1980, Williamsonce again took his case to the Court of Appeals for the Eighth Circuit. Here the appeals court reversed the district court's decision. The court of appeals ruled that in order for an inevitable discovery exception to the exclusionary rule to be considered valid, the state first must prove that the policedid not act in bad faith, then prove that the evidence would have been "inevitably discovered." The appeals court concluded that Iowa did not meet the first condition--proving that the police did not act in bad faith. The appeals court agreed with the district court that the state did prove, by a preponderance of the evidence, that the body would have been found. However, this, in their opinion, was irrelevant because the state failed to show that the policeacted in good faith.
Supreme Court Approves Inevitable Discovery Exception
On 18 January 1984 the Supreme Court granted certiorari to review thesecond Williams case. When the Supreme Court grants certiorari it means that it has agreed to review a case on the basis of its appellate jurisdiction. Chief Justice Burger wrote the opinion of the Court, which reversed thedecision made by the Court of Appeals for the Eighth Circuit. To this point,most state supreme courts acknowledged the merit of an inevitable discovery exception to the exclusionary rule. The matter was now before the U.S. SupremeCourt whose ruling would have considerable bearing on the way future cases involving the exclusionary rule would be decided.
In his opinion, Burger cited Silverthorne Lumber Co. V. United States(1920) and Wong Sun v. United States (1963) both of which strengthenedthe exclusionary rule. He also astutely pointed out that in both rulings theCourt had allowed room for exceptions to the exclusionary rule. More importantly, Burger noted that in Wong Sun, the Court held that the state does not have to prove "good faith" in order for evidence to be admitted. This was the basis upon which the appeals court had reversed the district court's ruling in the Williams case. In the opinion Burger reiterated that the reasoning behind the exclusionary rule was to prohibit law enforcement officials from violating constitutional rights in their pursuit of criminals. He noted, however, that not all evidence, or "fruit," obtained by unlawful interrogations, is inadmissible. This, he emphasized, is the point of the independent source doctrine. In simple terms, evidence that is found independent of a constitutional violation should not be thrown out.
Burger also addressed the argument made by Williams' defense which maintainedthat the exclusionary rule applies differently to the Fourth and Sixth Amendments. Williams argued that, with respect to the Fourth Amendment, the exclusionary rule is designed to prohibit unlawful police conduct. With respect tothe Sixth Amendment, the defense argued, the exclusionary rule is designed topurify the "fact-finding process." On this basis, the defense claimed that the Court should not decide the case on the basis of competing values--the social cost of excluding or admitting the evidence--but rather, the Court shouldmerely address whether the evidence was lawfully obtained. Burger rejected the argument on the grounds that excluding evidence that would have inevitablybeen found has no bearing on an individual's Sixth Amendment rights--whetherone has been granted a "fair trial."
Justice White offered a concurring opinion which was designed to temper someof the observations offered by Justice Stevens in his reluctant concurrence.Justice White restated an opinion he had made in the Courts ruling in Brewer v. Williams. In that case Justice White was of the opinion that Detective Leaming had done nothing wrong, and that the issue of "bad faith" was completely irrelevant. He added that there is no need to promote the view that Detective Leaming behaved improperly in his investigation. Justice Stevens concurred with the decision, however, he added that Detective Leaming could havesaved the state of Iowa considerable time and money had he behaved properly,and refrained from interrogating the suspect.
Dissenters Feel Exclusionary Rule is Undermined
Justices Brennan and Marshall offered a joint dissenting opinion arguing thatthe Court undermined the exclusionary rule by blurring the difference between the inevitable discovery doctrine and the independent source exception. Theindependent source doctrine, they stressed, applies only to evidence that was, in fact, found. Brennan and Marshall cautioned that allowing evidence to be admitted, which would have inevitably been discovered, could potentially impose on constitutionally protected rights. They therefore argue that the inevitable discovery exclusion, though sound in principle, should be subjected toa "heightened burden of proof."
Exclusionary Rule Offends Law and Order Supporters
Some politicians and judges take exception to the principle of excluding evidence from a trial because it was gathered in violation of an individual's constitutional rights. President Richard Nixon nominated two Supreme Court justices who reputedly opposed the exclusionary rule, Warren Burger and William Rehnquist. Burger was appointed in 1971 and Rehnquist in 1971. The majority ofthe Warren Court believed that law enforcement officials should not have investigations negated by technicalities. The Rehnquist Court has promoted the view in their decisions that the "good faith" test should be employed to determine whether evidence should ultimately be admitted.
In 1981, President Ronald Reagan denounced the exclusionary rule at a policeconvention. He stated that the exclusionary rule relies on the "absurd proposition that a law enforcement error, no matter how technical, can be used to justify throwing out an entire case" regardless of the nature of the crime andthe clarity of a persons guilt. Decisions offered by the Warren, Burger, andRehnquist Courts have generally aligned with this view, by broadening the exceptions to the exclusionary rule.
The exclusionary rule still survives, but the exceptions to it are growing. Nix v. Williams reflects the Burger-Rehnquist distaste for the exclusionary rule and provides an example of an exception to it, that of the "inevitable discovery" of evidence.
Related Cases

• Spano v. New York, 360 U.S. 315 (1959).
  
• Wong Sun v. United States, 371 U.S. 471 (1963).
  
• Chapman v. California, 386 U.S. 18 (1967).
  
• United States v. Wade, 388 U.S. 218 (1967).
  
• Brewer v. Williams, 430 U.S. 387 (1977).