Facts of the Case

In 1968, Robert Williams, who had recently escaped from a mental hospital, abducted and killed a 10-year-old girl in Iowa. After his arrest, during the car ride back to Des Moines, Williams was not provided an attorney, despite his previous requests for one. During the ride, police engaged Williams in conversation designed to elicit information about the location of the victim’s body. Eventually, Williams led the officers to the girl’s body, which was located in a remote area. This confession, obtained without the presence of Williams’ attorney, was suppressed in an earlier Supreme Court decision, Brewer v. Williams (1977), on the grounds that it violated his Sixth Amendment right to counsel.

However, in Nix v. Williams, the issue before the Court was whether the evidence of the body could be admitted under the “inevitable discovery” doctrine, despite the unconstitutional means by which it was obtained.

Constitutional Question

Does the “inevitable discovery” exception to the exclusionary rule allow for the admission of evidence that would have been discovered by lawful means, even if it was initially obtained in violation of the defendant’s Sixth Amendment rights?

Arguments

For Nix (the prosecution):

• The prosecution argued that the search teams were closing in on the location of the body at the time Williams led them to it, meaning that the body would have been discovered shortly, even without Williams’ improper confession.
• The “inevitable discovery” doctrine allows illegally obtained evidence to be admitted if it can be proven that the evidence would have been discovered through lawful means eventually.

For Williams:

• Williams’ defense argued that the exclusionary rule should apply because the police obtained the body through unconstitutional means, in violation of his right to counsel.
• The defense maintained that allowing the evidence would reward police misconduct and undermine the protection of constitutional rights.

The Decision

The Supreme Court, in a 7-2 decision, ruled in favor of Nix. Chief Justice Warren E. Burger, writing for the majority, held that the “inevitable discovery” doctrine allows evidence to be admitted if it can be shown that the evidence would have been discovered lawfully, regardless of the illegal actions by law enforcement. The Court reasoned that, in this case, the body of the victim would have been found by the search teams who were combing the area where the body was located. Thus, the discovery of the body was inevitable, and excluding the evidence would not serve the purpose of deterring police misconduct.

The Court noted that the exclusionary rule exists to deter unlawful police conduct, but in this instance, because the evidence would have been discovered anyway, suppression of the evidence was not warranted.

Significance

Nix v. Williams is a landmark case that firmly established the “inevitable discovery” exception to the exclusionary rule. The ruling allows evidence that was obtained illegally to be used in court if it can be proven that it would have been discovered lawfully, irrespective of the improper conduct that led to its initial discovery. This decision marked a significant limitation on the exclusionary rule, balancing the protection of defendants’ constitutional rights with practical considerations for law enforcement.

The case has had a profound impact on how courts handle situations involving illegally obtained evidence, providing law enforcement with more leeway when evidence would have been discovered through legitimate means.