Nix v. Williams

Nix v. Williams Case Brief

United States Supreme Court
467 U.S. 431 (1984)

ISSUE: Should the inevitable discovery doctrine apply to allow admission of evidence that would have been discovered if search teams continued as they would have if D had not led the police to the body?
HOLDING: Yes.
PROCEDURAL HISTORY:
  • At the 2nd trial, D's statements and the fact that D directed the police to the body were not admitted into evidence
    • Evidence of condition of the body, articles, photographs, and results of post mortem tests were admitted, however
  • Trial Ct. determined that the State proved by a preponderance that has the search not been suspended, V's body would have been discovered w/i a short time
  • Iowa Sup. Ct. affirmed
  • Dist. Ct. denied habeas petition, determining that the body would have inevitably have been found in much the same condition
  • Ct. App. reversed, holding that the State had not met the absence-of-bad-faith requirement for an inevitable discovery doctrine
RULES:
  • Exclusionary Rule: Applies not only to illegally obtained evidence itself, but also to other incriminating evidence derived from the primary evidence
  • Exceptions:
    • Independent Source Doctrine: Allows admission of evidence that has been discovered by means wholly independent of any constitutional violation
REASONING:
  • Inevitable Discovery Doctrine: If the prosecution can establish by a preponderance of the evidence that the information ultimately or inevitably would have been discovered by lawful means, then the evidence should be admitted into evidence
    • Excluding such evidence would put the police in a worse position then they would have been in, which is contrary to the interests of society
  • No absence-of-bad-faith req't: There is no requirement that the prosecution must prove the absence of bad faith
    • Such a req't would place courts in the position of withholding from juries relevant and undoubted truth that would have been available absent unlawful police conduct
    • Enormous societal costs
    • Officers will be deterred by the threat of departmental discipline and civil liability
  • Exclusion doesn't add to fairness at trial: Exclusion of physical evidence that would inevitably have been discovered adds nothing to either the integrity or fairness of a criminal trial
    • Reliability of evidence in no way affected here
    • Fairness can be achieved by placing the State and the D in the same position they would have been in but for the unlawful police conduct
  • Discovery inevitable here: Had Williams not led the police to V's body, the volunteer search teams would have found the body
    • Body was found in a culvert where the teams were told to look
    • Polk Cty. would have been searched just like the others (map obtained already)
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