Nix v. Williams Case Brief

Summary of Nix v. Williams, 432 US 1031(1975), 467 US 431(1984)

This case sets the ever-important precedent of “Inevitable Discovery".

Facts: The defendant, Williams, was charged with the abduction and first-degree murder of a young girl in Des Moines, Iowa. The defendant surrendered himself to local police in Davenport, Iowa and was arraigned on his charges and given counsel. Upon transport back to Des Moines, one of the officers notified the defendant that there was a possibility of snow that could jeopardize the recently begun search for the victim’s body. The defendant volunteered the location of the body and the search, which had neared the location of body, was cancelled.

First Trial

Procedural History: Williams was indicted on his charges in 1969. The defense moved to suppress all evidence attained as a result of the defendant’s statements to the police should be excluded as fruit of an unlawful police procedure in violation of the defendant’s right to counsel. They contested that the officer’s comments to the defendant constituted an unlawful interrogation, since he had retained counsel and were intended to produce inculpatory statements from him. Prosecution argued that the discovery of the body was inevitable, considering the search process and the obvious location of the body. The defense motion was denied and the result of his first trial in 1970 was a guilty verdict. His first appeal was affirmed but the second appeal to the Iowa Court of Appeals reversed the initial decision, as was the second appeal. Habeas Corpus was petitioned and granted. The subsequent courts decided to affirm and on appeal, Certiorari was granted.

Issue: Were the officer’s comments to the defendant in essence an unlawful interrogation in violation of his right to counsel?

Holding: The ruling of the lower court was reversed and a new trial was ordered with the exclusion of the evidence in question. This decision was rendered in 1975.

Rationale: William’s statements were ruled inadmissible as an interrogation in violation of his right to counsel.

Second Trial

Procedural History: At William’s second trial in 1977, prosecution did not offer his statements to the police into evidence, but did offer the body as evidence as if the body had been found without the notice of the defendant. The defense again argued to have the body not admitted as evidence, but was denied and the defendant was again found guilty of his charges. His first appeal to the Iowa Supreme Court was affirmed on the basis that the police were not acting in bad faith when the statements to the defendant were made and the fact that the body would have been inevitably been discovered during the police search. William’s second appeal reversed the lower court’s decision on the basis that it had not proven that the police had not acted in bad faith. Habeas Corpus and Certiorari for appeal from the state were again granted in 1983.

Issue: Is there an inevitable discovery exception to the exclusionary rule?

Holding: The lower court’s decision was reversed and a third trial was ordered with the admission of the evidence in question.

Rationale: The fact that the body of the girl would have been found in short order outweighs the defendant’s argument of an unlawful interrogation, a minor mistake, by the police.

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