Nix v. Williams
467 U.S. 431 (1984)
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Rule of Law:
Evidence obtained in violation of a defendant's constitutional rights is admissible if the prosecution can prove by a preponderance of the evidence that it would inevitably have been discovered by lawful means. This exception to the exclusionary rule does not require a separate inquiry into the good or bad faith of the police officers who committed the constitutional violation.
Facts:
- On December 24, 1968, 10-year-old Pamela Powers disappeared from a YMCA in Des Moines, Iowa.
- Robert Williams was seen leaving the YMCA carrying a large bundle, which a witness said contained 'two legs...skinny and white.'
- Williams surrendered to police in Davenport, Iowa on December 26. His attorney in Des Moines secured an agreement from police that they would not question Williams during the car transport back to Des Moines.
- During the drive, Detective Leaming gave Williams a 'Christian burial speech,' urging him to reveal the location of the girl's body before an impending snowstorm made it impossible to find.
- In response to the speech, Williams led the police to the victim's body.
- Contemporaneously, the Iowa Bureau of Criminal Investigation had initiated a large-scale search involving 200 volunteers, who were systematically checking roads, ditches, and culverts.
- When Williams agreed to lead police to the body, the search was called off. At that time, search teams were only two and a half miles from the body's location, and the body was found in an area that was part of the planned search grid.
Procedural Posture:
- Following an illegal interrogation, Williams was convicted of murder in an Iowa trial court (the first trial).
- The U.S. Supreme Court, in Brewer v. Williams, affirmed a grant of habeas corpus, finding the interrogation violated Williams' Sixth Amendment right to counsel.
- At a second trial, the prosecution introduced evidence of the victim's body, arguing it would have been inevitably discovered. The Iowa trial court admitted the evidence, and Williams was again convicted.
- The Iowa Supreme Court affirmed the second conviction, formally adopting an inevitable discovery exception to the exclusionary rule.
- Williams filed a second petition for a writ of habeas corpus in federal district court, which was denied.
- The U.S. Court of Appeals for the Eighth Circuit reversed, holding that the inevitable discovery exception requires the prosecution to prove the police did not act in bad faith.
- The State of Iowa, through Warden Nix, was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Is evidence obtained in violation of the Sixth Amendment right to counsel admissible if the prosecution proves by a preponderance of the evidence that it would have been inevitably discovered by lawful means, regardless of the police's good or bad faith?
Opinions:
Majority - Chief Justice Burger
Yes. Evidence that would inevitably have been discovered by lawful means is admissible. The Court formally adopts the inevitable discovery doctrine, reasoning that the purpose of the exclusionary rule is to deter police misconduct by ensuring the prosecution is not put in a better position than it would have been without the illegality. Conversely, excluding evidence that would have been lawfully found anyway would put the prosecution in a worse position, which is not the rule's goal. The prosecution must establish by a preponderance of the evidence that the discovery was inevitable. A requirement that the police must have acted in good faith is rejected, as it does not serve the balancing of interests at the core of the exclusionary rule and would result in the societal cost of excluding reliable evidence. Here, the systematic and progressing search by volunteers would have inevitably led to the discovery of the body.
Concurring - Justice White
Justice White joined the majority's opinion but wrote separately to note that he and three other justices in the original Brewer v. Williams case believed Detective Leaming's conduct was not unconstitutional at all. Therefore, characterizing the detective's actions as a deliberate, bad-faith violation of the law is an unjustified reflection on an officer who was acting as many competent officers would have under the circumstances.
Concurring - Justice Stevens
Justice Stevens concurred in the judgment only. He argued that the majority's focus on the Fourth Amendment's deterrence rationale was misplaced because this was a Sixth Amendment case, where the primary goal is to ensure a fair adversarial trial process. He characterized Detective Leaming's 'Christian burial speech' as a deliberate violation designed to substitute an inquisitorial process for the constitutionally required adversarial one. However, he concluded that admitting the body as evidence did not taint the trial process, because the body's existence and condition were objective facts that would have been discovered regardless of the constitutional violation. Therefore, the good or bad faith of the officer is irrelevant to whether the trial itself was fundamentally fair.
Dissenting - Justice Brennan
Justice Brennan, joined by Justice Marshall, agreed in principle with the inevitable discovery exception but dissented from the majority's holding. He argued that because the finding of 'inevitable discovery' is hypothetical, it differs significantly from the 'independent source' doctrine. To protect the rights served by the exclusionary rule and to ensure the exception is narrowly applied, he would require the prosecution to prove inevitability by a higher standard of clear and convincing evidence, not merely a preponderance of the evidence. Since the lower courts did not apply this heightened standard, he would have remanded the case.
Analysis:
This case is significant for formally adopting the 'inevitable discovery' doctrine as an exception to the exclusionary rule. The decision clarifies that the exception applies to Sixth Amendment right-to-counsel violations, not just Fourth Amendment violations. By setting the burden of proof at a 'preponderance of the evidence' and rejecting a 'good faith' requirement for police, the Court made the doctrine more accessible to prosecutors. This ruling reflects a balancing act, weighing the deterrent effect of the exclusionary rule against the high societal cost of excluding reliable, probative evidence of guilt from a criminal trial.
