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Nix v. Williams

Supreme Court of the United States · 1984 · Criminal Procedure

Criminal ProcedureFourth Amendmentexclusionary ruleinevitable discoverySixth Amendmentfruit of the poisonous treeinevitable discoveryindependent source

Facts

While volunteers were conducting a large-scale search for a missing child's body along the route police believed Williams had traveled, detectives transported Williams from Davenport to Des Moines after he had surrendered and been arraigned. During the trip, Detective Leaming made statements that this Court had previously held amounted to interrogation in violation of Williams' right to counsel, and Williams then led police to the child's body. At Williams' second trial, the prosecution did not introduce his statements or testimony that he led police to the body, but it did introduce evidence of the body's location and condition, clothing, and autopsy results. The state trial court found by a preponderance of the evidence that the volunteer search would have found the body within a short time and in essentially the same condition even without Williams' statements.

Issue

Whether evidence concerning the discovery and condition of the victim's body was admissible at Williams' second trial on the ground that it ultimately or inevitably would have been discovered by lawful means, despite the prior Sixth Amendment violation. Also, whether the inevitable discovery doctrine requires the prosecution to prove an absence of police bad faith.

Rule

If the prosecution establishes by a preponderance of the evidence that the challenged information ultimately or inevitably would have been discovered by lawful means, the evidence is admissible under the inevitable discovery exception to the exclusionary rule. The doctrine does not require the prosecution to prove the absence of bad faith by the police.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Kansas City, Missouri, police violated a charged suspect’s Sixth Amendment right to counsel by deliberately eliciting remarks during transport. The suspect then directed officers to a backpack containing a knife in a drainage ditch. At the time of the violation, a lawful fire-department search team was already moving block by block through that same flood channel under a preplanned grid search and would have reached the ditch within 30 minutes.

Is the knife admissible at trial?

Explanation. The majority adopted the inevitable discovery exception: challenged evidence is admissible if the prosecution establishes by a preponderance of the evidence that the information ultimately or inevitably would have been discovered by lawful means. The doctrine applies even when the initial constitutional violation was of the Sixth Amendment. The Court rejected both a clear-and-convincing burden and any separate good-faith requirement.