Nix v. Williams

On 18 January 1984 the Supreme Court granted certiorari to review the second 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 the decision 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. Supreme Court 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 strengthened the exclusionary rule. He also astutely pointed out that in both rulings the Court 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 maintained that 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 to the Sixth Amendment, the defense argued, the exclusionary rule is designed to purify 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 should merely address whether the evidence was lawfully obtained. Burger rejected the argument on the grounds that excluding evidence that would have inevitably been found has no bearing on an individual's Sixth Amendment rights--whether one has been granted a "fair trial."

Justice White offered a concurring opinion which was designed to temper some of 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 have saved the state of Iowa considerable time and money had he behaved properly, and refrained from interrogating the suspect.