The U.S. Supreme court reversed the Court of Appeals.

82-1651.

Robert Anthony Williams.

The prosecution relied on the location of the body, the autopsy report, and the clothing that was found to support their arguments. Williams' conviction was thereby upheld.

Following the disappearance of a 10-year-old girl in Des Moines, Iowa, respondent was arrested and arraigned in Davenport, Iowa. It acknowledged an inevitable discovery rule, but found it did not apply because the police acted in bad faith. It held that the “Christian Burial Speech” was interrogation in violation of Williams’s Sixth Amendment rights.

The independent source doctrine simply means that evidence can be allowed if it is discovered independent of a constitutional violation. Nix v. Williams Significance, Supreme Court Approves Inevitable Discovery Exception, Dissenters Feel Exclusionary Rule Is Undermined, Exclusionary Rule Offends Law And Order Supporters. Terms of Use, Nix v. Williams - Supreme Court Approves Inevitable Discovery Exception, Law Library - American Law and Legal Information, Notable Trials and Court Cases - 1981 to 1988, Nix v. Williams - Significance, Supreme Court Approves Inevitable Discovery Exception, Dissenters Feel Exclusionary Rule Is Undermined, Exclusionary Rule Offends Law And Order Supporters.

The evidence pertaining to the discovery and condition of the victim's body was properly admitted at respondent's second trial on the ground that it would ultimately or inevitably have been discovered even if no violation of any constitutional provision had taken place.

Accordingly, the evidence at trial, namely the victim’s body, was admissible despite the police violation of Williams’s Sixth Amendment rights.

[5], Williams then received a second trial, in which his attorneys again moved to suppress all evidence stemming from the interrogation of Williams by the detectives.

Nix v. Williams (Williams II) Citation467 U.S. 431, 104 S. Ct. 2501, 81 L. Ed.

State law enforcement officials of Iowa, along with 200 volunteers, began to search the area between Grinnell and Des Moines in an effort to recover the body. 467 U.S. 431. The U.S. Supreme Court granted certiorari. In Williams's second trial in Iowa state court, the prosecution adhered to the U.S. Supreme Court's ruling, and refrained from offering Williams's statements, including his pointing out where the body was, as evidence. In the event that a retrial is instituted, it will be for the state courts in the first instance to determine whether particular items of evidence may be admitted. In the twenty-five years since Nix was decided, a pattern has developed in which every few years, legal scholars try to determine whether the inevitable discovery exception should apply to new factual scenarios. The judge ruled that Williams' statements to the detectives were inadmissible, but citing Stewart's footnote, ruled that the body was admissible as evidence, as it would have inevitably been discovered by law enforcement. Williams ultimately agreed to show the police where the body was and made self incriminating statements in the process.

State law enforcement officials engaged in a massive search for the child's body. The appeals court concluded that Iowa did not meet the first condition--proving that the police did not act in bad faith. Williams was later charged and convicted of first-degree murder.

State law enforcement officials engaged in a search for the child’s body.

The Court ruled that, indeed, the Iowa police had violated Williams's Sixth Amendment right to counsel by interrogating him in the car.

The Court stated that law enforcement was not required to demonstrate that it had violated a defendant's rights in good faith, only that the evidence would have inevitably been found despite the violation. Yet, removing his conduct and its resulting evidence out of the equation, the victim’s body is admissible at trial if it ultimately would have been found anyway. Williams was tried and convicted a second time. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT Syllabus. One of the detectives began a conversation and proposed that Williams reveal where he had left the body before an impending snowfall; Williams agreed and led the detectives to Powers' body.[3].

It found that even if Williams did not lead police to the body, the search party would inevitably have found it. Concurring in the judgment only, Justice Stevens believed that the Court’s majority opinion failed to address the clear constitutional violation by Detective Leaming. The victim’s body was entered into evidence at that trial. Nix v. Williams Significance. On a habeas petition, the Federal District Court denied the petition, relying on the inevitable discovery rule.

v. Varsity Brands, Inc. Williams was convicted of murder. On habeas petition, the Eighth Circuit Court of Appeals reversed, stating that the government had to prove an absence of police bad faith before the inevitable discovery rule could apply.

The exclusionary rule makes most evidence gathered through violations of the Fourth Amendment to the United States Constitution, which protects against unreasonable search and seizure, inadmissible in criminal trials as "fruit of the poisonous tree". Respondent. https://supreme.justia.com/cases/federal/us/467/431/case.html. Significance: Nix v. Williams solidified the application of the inevitable discovery doctrine as an exception to the exclusionary rule in criminal cases. This agreement precluded the need for a Davenport attorney to escort Williams back to Des Moines. The jury at the second trial convicted Williams of first-degree murder. The Iowa state court disagreed, and the Iowa Supreme Court upheld the decision. Iowa authorities suspected Robert Anthony Williams, who was observed placing what appeared to be a human body wrapped in a blanket into his car the same evening at the YMCA. Williams subsequently appealed to the Iowa Supreme Court where it was ruled that the body was admissible on the basis of what is known as the "independent source doctrine."

Petitioner's Claim. Four members of the Court in Brewer v. Williams thought Leaming did nothing wrong. Williams’: Date of the Trial: Nix V. Williams was decided in 1984. The majority opinion was written by Chief Justice Warren E. Burger, who was joined by Justices Byron White, Harry Blackmun, Lewis F. Powell, Jr., William Rehnquist, and Sandra Day O'Connor. Williams and his defense, however, did not surrender their position.

All Rights Reserved Nix v. Williams solidified the application of the inevitable discovery doctrine as an exception to the exclusionary rule in criminal cases.
When Williams surrendered to police in Davenport, the search had been well under way. [1], Robert Williams, an escaped mental patient, murdered ten-year-old Pamela Powers after kidnapping her from a YMCA in Des Moines, Iowa, on December 24, 1968. On appeal, the state courts affirmed the conviction. 2d 377 (1984) Brief Fact Summary. Because of that important distinction, the government should be required to prove the inevitable discovery by a heightened standard — clear and convincing evidence. Yes.

Williams was arrested at a rest stop the next day in Davenport, Iowa.
Further, it is not necessary for the government to prove an absence of bad faith (as the lower courts suggested). The majority in Nix v. Williams also appears to be pleased that it was able, after two Williams cases, to finally affirm the conviction of a person who committed a particularly heinous crime.