NIX v.

WILLIAMS

FACTS:

1. On December 24, 1968, 10 year-old Pamela Powers disappeared from a YMCA building in Des
Moines, Iowa where she accompanied her parents to watch an athletic contest.
2. Shortly after she disappeared, Williams was seen leaving the YMCA carrying a large bundle
wrapped in a blanket. The 14-year-old boy who had helped Williams open his car door reported
that he had seen "two legs in it and they were skinny and white."
3. The next day, Williams’ car was found 160 miles east of Des Moines in Iowa while several
clothing belonging to the child and a similar army blanket like the one used to wrap the
bundle that Williams carried out of the YMCA were found at a rest stop.
4. A warrant of arrest was then issued against Williams.
5. The Iowa Bureau of Criminal Investigation initiated a large-scale search wherein around
200 volunteers began to search 21 miles east of Grinnell, covering an area several miles to
the north and south of Interstate 80.
6. Subsequently, Williams surrendered to local police in Davenport where he was arraigned.
Two Des Moines detectives then drove to Davenport, took Williams into custody, and proceeded
to drive him back to Des Moines.
7. During the drive, Detective Leaming said to Williams that the snow fall may make it difficult to find
the girl’s body, and that it would be a shame if the girl’s family would not be able to give her a
“Christian burial.” In response to Leaming’s speech, Williams directed the police officers to the
girl’s body. (N.B. Body was found within the area also to be searched by the volunteers)
8. FIRST TRIAL
a. During trial, Williams was indicted for first degree of murder.
b. Before trial, his counsel moved to suppress evidence of the body and all related
evidence including the condition of the body as shown by the autopsy for such evidence
was the "fruit” or product of Williams' statement made during the automobile ride
from Davenport to Des Moines and prompted by Leaming's statements.
c. The motion to suppress was denied and Williams was found guilty of the first degree of
murder by the jury. The judgment of conviction was affirmed by the Iowa Supreme Court.
d. WILLIAMS THEN SOUGHT RELEASE ON HABEAS CORPUS IN US DISTRCIT
COURT FOR SOUTHERN DISTRICT OF IOWA.
i. Court granted it on the ground that the EVIDENCE WAS WRONGFULLY
ADMITTED and Detective Leaming had obtained incriminating statements
from Williams by what was viewed as interrogation in violation of his right
to counsel.
ii. Although incriminating statements could not be introduced, evidence of the
body's location and condition "might well be admissible on the theory that
the body would have been discovered in any event, even had incriminating
statements not been elicited from Williams.”
9. SECOND TRIAL
a. The prosecution did not offer Williams’ statements into evidence nor did it seek to show
that Williams had directed the police to the child's body.
b. However, evidence of the condition of her body as it was found, articles and photographs
of her clothing, and the results of post mortem medical and chemical tests on the body
were admitted.
c. Trial court: had proved by a preponderance of the evidence that, if the search had not
been suspended and Williams had not led the police to the victim, her body would
 have been discovered "within a short time" in essentially the same condition as it
was actually found.
d. In finding that the body would have been discovered in essentially the same condition as
it was actually found, the court noted that freezing temperatures had prevailed and tissue
deterioration would have been suspended.
e. Williams was then found guilty of the crime charged by the jury.
f. On appeal, the Iowa Supreme Court affirmed. It found that even if Williams did not
lead police to the body, the search party would inevitably have found it.
g. On a habeas petition, the Federal District Court denied the petition, relying on the
inevitable discovery rule.
h. The Eighth Circuit Court of Appeals reversed. It acknowledged an inevitable
discovery rule, but found it did not apply because the police acted in bad faith.

ISSUE:

W/N evidence that would otherwise be excluded from trial because of the police’s constitutional violation
still be admissible if it would inevitably have been discovered by legal means? YES.

HELD:

Unconstitutionally obtained evidence can still be admitted at trial if that evidence would have
inevitably been discovered through lawful means.

The independent source doctrine, which allows admission of evidence that was found through means
wholly independent of any constitutional violation, does not directly apply to this case; however, its
rationale justifies the adoption of the “inevitable discovery” exception to the exclusionary rule here.
While exclusion of evidence is appropriate if there is a constitutional violation by the government,
the government should not be placed in a worse position by excluding the evidence that would
have ultimately been found by other lawful means.

Further, it is not necessary for the government to prove an absence of bad faith (as the lower courts
suggested). In this case, the evidence showed that the 200-volunteer search party was close
enough to the victim’s body that it would have found the body within a short time had Williams
not cooperated with police. Accordingly, the evidence at trial, namely the victim’s body, was admissible
despite the police violation of Williams’s Sixth Amendment rights.