Nix v. Williams

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 would be admissible. This ruling is one example of the Burger Court's broadening of the 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 a blanket into his car the same evening at the YMCA. Williams was arrested at a rest stop the next day in Davenport, Iowa. The police found clothes belonging to Pamela Powers, the missing girl, clothing of Williams, and a blanket at a rest stop between Des Moines and Davenport. They presumed that Williams must have hidden the body somewhere between Des Moines and Grinnell, where they found clothes and blanket.

State law enforcement officials of Iowa, along with 200 volunteers, began to search 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 have a Davenport attorney escort Williams back to Des Moines with the police. The law 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 hidden and, because snow was forecast for that evening, he could save the family and community 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 police where the body was and made self incriminating statements in the process. The search 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 argued that 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 Court upheld the decision. Upon being sentenced to life in prison for first degree murder, 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. The Court 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 grounds that 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 clothing that 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, Williams once 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 police did 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 police acted in good faith.