Reference no: EM13814789
TITLE AND CITATION: Nix v. Williams, 467 U.S. 431, 104 S.Ct. 2501 (1984)
TYPE OF ACTION: Review by the U.S. Supreme Court of a lower court ruling that evidence should be suppressed as a result of a violation of the Sixth Amendment right to counsel. The state (Nix) sought to overturn the motion to suppress that was upheld by the U.S. District Court of Appeals.
FACTS OF THE CASE:
On December 24, 1968, ten year old Pamela Powers was kidnapped from an Iowa YMCA and her body was later found in a ditch, which was within an extensive area that was being searched by volunteers and law enforcement. The defendant was observed "carrying a large bundle wrapped in a blanket...two legs in it and they were skinny and white." Williams' car, which contained clothing items belonging to the victim, was found the next day approximately 160 miles from the incident. Based on this information, an extensive search was started that extended from Des Moines to Davenport, Iowa.
Law enforcement obtained a warrant for Williams' arrest, and he subsequently turned himself into the authorities in Davenport. Williams was arraigned and had obtained and spoken with an attorney. Des Moines police detectives agreed to transport Williams and not interview him during the drive between Davenport and Des Moines. During the drive, one of the detectives on the case began to speak to Williams regarding the need to find the child's body before it snowed so that her parents could give her a proper, "Christian" burial. The detective did not ask Williams any specific questions during this conversation. At that point, Williams provided statements to the detectives that led them to the child's body.
Williams was then tried in state court and was found guilty of first degree murder. Williams filed a motion to suppress the evidence of the body and all related evidence concerning the body's location based on illegally obtained testimony. When the conviction was affirmed by the Iowa state Supreme Court, Williams sought relief in the U.S. District Court for the Southern District of Iowa. The U.S. District Court, U.S. Court of Appeals, and the U.S. Supreme Court agreed with Williams and determined that he was denied the right to counsel and his statements, which led to the child's body, could not be introduced into evidence.
Williams was tried in state court a second time, without the use by the prosecution of the statements he had given to detectives. Prosecutors introduced evidence of the child's body under the premise of "inevitable discovery", as the child's body was in an area that was within the designated search area. Williams was convicted a second time and the conviction was upheld by the Iowa Supreme Court again. Appeals by the parties brought the case back to the U.S. Supreme Court a second time.
CONTENTIONS OF THE PARTIES:
Nix: The state (Nix) contends that the evidence of the child's body and all related evidence concerning the body as to its location should be admissible in spite of the denial of right to counsel because the body would have been discovered in any event due to the wide-ranging search in the area which was not the result of anything that Williams said to the detectives. In the second trial, the defendant's statements were not introduced, but the body evidence should still be admissible because it would have been discovered and in the same condition anyway even if there was no violation of the Sixth Amendment. The child's body was found well within the extensive search area and would have been located by one or more of the over two hundred searchers nearly the same time that the defendant took the detectives to the child's body. This argument is called the "inevitable discovery rule."
Williams: Williams contends that were it not for the illegally obtained statements from Williams by law enforcement, the evidence would not have been discovered or used against the defendant. The evidence obtained is considered the "fruit of the poisonous tree," and therefore should not be admitted at trial.
ISSUE: Once a violation of the Sixth Amendment right to counsel has occurred, can evidence obtained from the illegally-obtained statements be admitted at trial based on the fact that the evidence would have been discovered anyway?
DECISION: Yes, because the prosecution was able to prove that the same physical evidence would have been discovered even if the constitutional rights violation did not occur.
REASONING: The court applied the reasoning of the independent source doctrine to that of inevitable discovery. "The independent source doctrine teaches us that the interest of society in deterring unlawful police conduct and the public interest in having juries receive all probative evidence of a crime are properly balanced by putting the police in the same, not a worse, position that they would have been in if no police error or misconduct had occurred" (quoting from Nix v. Williams, 104 S.Ct. 2501, 2509 (1984)).
RULE OF LAW: Evidence that may have been obtained in violation of a constitutional protection may still be admissible if it can be proven by a preponderance of the evidence that it was inevitable that the evidence would have been discovered even if the violation had not occurred. This is known as the "inevitable discovery" rule.