Facts of the Case

In 1968, Robert Williams, who had recently escaped from a mental institution, was arrested for the abduction and murder of a 10-year-old girl, Pamela Powers, in Des Moines, Iowa. After Williams was arrested and had invoked his right to counsel, police officers decided to transport him from Davenport to Des Moines, a 160-mile journey. Williams’ attorney had instructed police not to question Williams during the trip, and Williams himself had requested to speak with a lawyer before answering any questions.

During the transport, one of the officers began a conversation with Williams, known as the “Christian burial speech.” The officer suggested that Williams should reveal the location of the girl’s body so that she could receive a proper Christian burial, appealing to Williams’ religious sensibilities. As a result, Williams eventually led the officers to the location of the body. His statements and the evidence obtained from them were later used against him in court.

Williams challenged his conviction, arguing that the statements leading to the discovery of the body were obtained in violation of his Sixth Amendment right to counsel, which he had already invoked.

Constitutional Question

Did the police officers violate Williams’ Sixth Amendment right to counsel by eliciting statements from him after he had already requested an attorney, and should the evidence (the location of the body) be excluded?

Arguments

For Williams:

• Williams’ defense argued that his right to counsel had been violated when the police intentionally elicited information from him after he had invoked his right to an attorney.
• The defense claimed that the officers’ use of the “Christian burial speech” was a deliberate attempt to bypass Williams’ constitutional rights and that the evidence obtained as a result should be excluded under the exclusionary rule.

For the State (Brewer):

• The state argued that Williams’ statements were voluntary and that he had not been explicitly interrogated.
• The state also claimed that even if there was a violation, the evidence should still be admissible under the “inevitable discovery” doctrine, meaning the body would have eventually been found by search teams without Williams’ help.

The Decision

The Supreme Court, in a 5-4 decision, ruled in favor of Williams, holding that his Sixth Amendment right to counsel had been violated. The Court found that the police had deliberately elicited incriminating information from Williams without providing him access to his attorney, despite his clear request for counsel. Justice Potter Stewart, writing for the majority, emphasized that once a defendant invokes their right to counsel, law enforcement may not interrogate them without their attorney present.

The Court also rejected the argument that the statements were voluntary, stating that the “Christian burial speech” was an interrogation intended to extract information from Williams without violating the formal rules against questioning.

However, the Court did not address the “inevitable discovery” argument, which would be later addressed in Nix v. Williams (1984).

Significance

Brewer v. Williams is a landmark case in the interpretation of the Sixth Amendment’s right to counsel. The ruling reinforced that once a defendant invokes their right to an attorney, any further interrogation by law enforcement must cease until counsel is provided. This case helped clarify the protections afforded to defendants during police interrogations and is frequently cited in cases involving the rights of individuals in custody.

Additionally, the case set the stage for the subsequent development of the “inevitable discovery” doctrine in Nix v. Williams, which allowed illegally obtained evidence to be admitted if it would have been discovered through legal means independently.