Review of nix vs. williams

The exclusionary rule prevents illegally obtained evidence to be used against a suspect charged with a crime. However, there are three exemptions to the exclusionary rule. One of these exemptions is known as the Inevitable Discovery Doctrine. This allows for evidence to be used, even if it was collected illegally, if the prosecution can show that the evidence would have been discovered from a hypothetical, independent source. The Supreme Court created this doctrine when they ruled on the case of Nix v. Williams.

On December 24, 1968, a 10 year old girl disappeared from her family at a local YMCA. At about that time, Williams was seen leaving the area carrying a large bundle in a blanket. A boy saw two legs sticking out of the bundle. The next day Williams’ car was found approx 160 miles east of the YMCA. Along the road, the police found several items that belonged to the missing girl, as well as items that belonged to Williams. At this point a warrant was issued for Williams’ arrest.

During the trip to Des Moines, one of the policemen started talking to Williams, making statements to elicit a guilty feeling. He made comments referring to how he wished he could give the girl a Christian burial for her family before Christmas. He went on to say that since they would be passing the area the body was buried on the way, he wish he knew where to look. Williams directed the police to where he had buried the body of the girl. At that time, the search party was only 2 miles from the body, and would have eventually been covered by the search team.

In February of 1969, Williams was indicted of first degree murder. His lawyer moved to suppress all evidence that came from the discovery of the body. His reasoning was that the body was the “fruits” of illegal interrogation by the police. The judge denied the motion, and the jury convicted Williams of first degree murder. On appeal, it was ruled that the statements by the police could be considered interrogation, and therefore violated Williams’ rights. They went on to state that during a second trial, statements made by Williams could not be used, however the body itself could, as it would have been discovered, even without the help of Williams.

During the second trial, the prosecution was able to use the body, and show its condition. However, they made no reference to Williams knowing the location of the body, or other statements Williams had made. The court had concluded by a preponderance of the evidence, that had Williams not lead police to the body, the search would have found it within a short period of time, in the same condition it was found. Williams was again convicted of first degree murder.

On appeal, the Supreme Court of Iowa affirmed the conviction, stating a “hypothetical independent source” as an exception to the exclusionary rule. The Court stated that “After the defendant has shown unlawful conduct on the part of the police, the State has the burden to show by a preponderance of the evidence that (1) the police did not act in bad faith for the purpose of hastening the discovery of the evidence in question, and (2) that the evidence in question would have been discovered by lawful means.” Id., at 260.

When applying these principals to the current case, the court found that the police had not acted in bad faith, and that the lawful activity of the search would have come to discover the body on its own before the body would have suffered a change in condition.

Upon another appeal, the decision was overturned, and the case remanded for retrial. The Court of Appeals agreed with the previous courts concept of inevitable discovery, but did not feel that the prosecution proved that the police did not act in bad faith. The case eventually made its way from appeal to appeal until it found itself before the Supreme Court of the United States.

The ruling of the Supreme Court stated that the point of the protections within the exclusionary rule are to act as safeguards of the adversary system. In that regard, fairness is assured when both the State and the defendant are in the same positions they would have been had the illegal police act not taken place. The Supreme Court went on to state, that by suppressing the body, the prosecution would be at a disadvantage compared to the situation prior to the illegal police conduct. They agreed with the three previous court opinions in that the police search would have located the body on its own, without the illegally seized testimony from Williams. Therefore, the Supreme Court reversed the previous decision for a retrial, which in effect affirmed the original trial in which Williams was found guilty.

This decision greatly effects how investigations are handled. Previously, it was understood that the exclusionary rule was used as a punishment against the state when their investigations broke the law. With this ruling, the state may violate a suspects rights, and the illegally collected evidence can still be admissible, as long as the prosecution can show that they would have come along to discover the evidence anyway. This has opened the door for more diligent and assiduous investigations, that had previously been closed off to investigators.