Nix V. Williams Summary
Case Citation: Nix v. Williams - 467 U.S. 431 (1984)
Facts: In 1968, 10 year old Pamela Powers was abducted and murdered outside of the YMCA in Des Moines, Iowa. A young boy claimed to have seen Williams, outside the YMCA carrying a bundle wrapped in a blanket with two white legs hanging out. The following day Williams, car was spotted approximately 160 miles outside of Des Moines. Additionally, several of the young girls clothing items were found. ; Along with Williams and with the blanket as described by the witness. Based upon these findings, a warrant was issued for Williams’ arrest. While a search was under way, Williams surrendered to the Davenport police, and obtained counsel. Des Moines police advised Williams counsel that they …show more content…
would not question him while transporting him back to Des Moines. However during transport, one of the officers began a conversation with Williams, and urged him to tell them where the body was located, so she could have a “proper Christian burial.” Williams conceded, and directed them to the girl’s body, which was over two miles from the closest search team.
Procedural History: Williams filed a motion to suppress the evidence of the body, because it was obtained as fruit of an unlawful interrogation. The court denied this motion, and Williams was subsequently convicted by a jury of first degree murder. The trial court denied the motion, and a jury convicted Williams of first-degree murder. Williams’s state appeal was affirmed by The Iowa Supreme Court. Williams then petitioned the United States District Court for the Southern District of Iowa for a writ of habeas corpus, and the court reversed the conviction. The court held that the evidence should have been suppressed. During Williams’ second trial, the prosecution did not offer evidence of the interrogation; however evidence was presented in regards to the condition of the victims body. The trial court allowed this evidence, and concluded that the prosecution had shown by a preponderance of the evidence that the victim’s body would have been discovered without Williams’ help. Williams was again convicted by a second jury and sentenced to life in prison. Upon another appeal, the Supreme Court of Iowa affirmed the conviction and the U.S. District Court denied habeas corpus relief. The U.S. Court of Appeals reversed the district court's denial of habeas corpus. The matter then came up before the Supreme Court in certiorari.
Issue: Should illegally obtained evidence become admissible in state court if it would have been ultimately discovered by lawful means?
Holding: Yes.
Evidence that is obtained through unlawful police conduct that would have been discovered inevitably during the course of an investigation does not have to be excluded from trial
Reasoning: Justice Burger wrote the decision of the Court, joined by Justice White, Justice Blackmun, Justice Powell, Justice Rehnquist and Justice O’Connor, and reversed the decision of the appellant court.
1.) The Inevitable Discovery Rule
If the prosecution is able to establish through a preponderance of evidence that the information ultimately would have been discovered lawfully, then the evidence should be allowed. It was inevitable that the body would have been found. If Williams had not led the police to the victim’s body, the search teams would have eventually discovered the body. The body was located only 2 and half miles away from where the nearest search team originally started looking.
2.) Exclusion would not result in fairness.
Evidence has demonstrated that at the time of unconstitutional interrogation, a search was already in place for the victim, and the body would have inevitably been found. This means had there not be illegal conduct by the police officers, the fairness of the trial would have remained the
same.
3.) Absence of bad faith is not required
The justices held that in order to establish the admissibility of evidence, the prosecution does not need to carry the burden of proving the absence of bad faith to secure the evidence
Concurrence: Justices White concurred with the holdings, but added that the police officer's action was not unlawful or unconstitutional
Justice Stevens, concurred with the holding, however advised that the police officer’s conduct was unconstitutional however because the body would have been discovered anyway the prosecution should be held harmless. Dissent: Justices Brennan and Marshall both dissented stating that though the inevitable discovery doctrine is constitution, the prosecution had the burden of prove that the evidence would have been discovered if an independent investigation were allowed to be proceed.
Comments: This case resulted in the creation of the Inevitable Discovery Doctrine. However I believe that it undermines the “fruit of the poisonous tree” doctrine, and enable law enforcement misconduct. The justices stated that the evidence supports that body would have been found with or without a confession. One might argue that a correctional officer can beat an inmate that is on death penalty to death, because he was going to be killed by the state anyway.
Facts: In 1968, 10 year old Pamela Powers was abducted and murdered outside of the YMCA in Des Moines, Iowa. A young boy claimed to have seen Williams, outside the YMCA carrying a bundle wrapped in a blanket with two white legs hanging out. The following day Williams, car was spotted approximately 160 miles outside of Des Moines. Additionally, several of the young girls clothing items were found. ; Along with Williams and with the blanket as described by the witness. Based upon these findings, a warrant was issued for Williams’ arrest. While a search was under way, Williams surrendered to the Davenport police, and obtained counsel. Des Moines police advised Williams counsel that they …show more content…
would not question him while transporting him back to Des Moines. However during transport, one of the officers began a conversation with Williams, and urged him to tell them where the body was located, so she could have a “proper Christian burial.” Williams conceded, and directed them to the girl’s body, which was over two miles from the closest search team.
Procedural History: Williams filed a motion to suppress the evidence of the body, because it was obtained as fruit of an unlawful interrogation. The court denied this motion, and Williams was subsequently convicted by a jury of first degree murder. The trial court denied the motion, and a jury convicted Williams of first-degree murder. Williams’s state appeal was affirmed by The Iowa Supreme Court. Williams then petitioned the United States District Court for the Southern District of Iowa for a writ of habeas corpus, and the court reversed the conviction. The court held that the evidence should have been suppressed. During Williams’ second trial, the prosecution did not offer evidence of the interrogation; however evidence was presented in regards to the condition of the victims body. The trial court allowed this evidence, and concluded that the prosecution had shown by a preponderance of the evidence that the victim’s body would have been discovered without Williams’ help. Williams was again convicted by a second jury and sentenced to life in prison. Upon another appeal, the Supreme Court of Iowa affirmed the conviction and the U.S. District Court denied habeas corpus relief. The U.S. Court of Appeals reversed the district court's denial of habeas corpus. The matter then came up before the Supreme Court in certiorari.
Issue: Should illegally obtained evidence become admissible in state court if it would have been ultimately discovered by lawful means?
Holding: Yes.
Evidence that is obtained through unlawful police conduct that would have been discovered inevitably during the course of an investigation does not have to be excluded from trial
Reasoning: Justice Burger wrote the decision of the Court, joined by Justice White, Justice Blackmun, Justice Powell, Justice Rehnquist and Justice O’Connor, and reversed the decision of the appellant court.
1.) The Inevitable Discovery Rule
If the prosecution is able to establish through a preponderance of evidence that the information ultimately would have been discovered lawfully, then the evidence should be allowed. It was inevitable that the body would have been found. If Williams had not led the police to the victim’s body, the search teams would have eventually discovered the body. The body was located only 2 and half miles away from where the nearest search team originally started looking.
2.) Exclusion would not result in fairness.
Evidence has demonstrated that at the time of unconstitutional interrogation, a search was already in place for the victim, and the body would have inevitably been found. This means had there not be illegal conduct by the police officers, the fairness of the trial would have remained the
same.
3.) Absence of bad faith is not required
The justices held that in order to establish the admissibility of evidence, the prosecution does not need to carry the burden of proving the absence of bad faith to secure the evidence
Concurrence: Justices White concurred with the holdings, but added that the police officer's action was not unlawful or unconstitutional
Justice Stevens, concurred with the holding, however advised that the police officer’s conduct was unconstitutional however because the body would have been discovered anyway the prosecution should be held harmless. Dissent: Justices Brennan and Marshall both dissented stating that though the inevitable discovery doctrine is constitution, the prosecution had the burden of prove that the evidence would have been discovered if an independent investigation were allowed to be proceed.
Comments: This case resulted in the creation of the Inevitable Discovery Doctrine. However I believe that it undermines the “fruit of the poisonous tree” doctrine, and enable law enforcement misconduct. The justices stated that the evidence supports that body would have been found with or without a confession. One might argue that a correctional officer can beat an inmate that is on death penalty to death, because he was going to be killed by the state anyway.