Nix v. Williams

In Nix v. Williams, 467 U.S. 431 (1984), an unconstitutional police interrogation led to the discovery of a murder victim's body. The Supreme Court held that evidence concerning the body and its location was nevertheless admissible because an independent search that was already underway inevitably would have led to the discovery of the body. The exclusionary rule should not be applied, the Court said, because its application would put the prosecution in a worse position than it would have occupied without the constitutional violation. Id. 467 U.S. 431 at 442-43. In Nix, the line of investigation that would inevitably have led to the discovery of the victim's body was entirely independent of the illegal interrogation that in fact led police to the body. Whether such independence of the alternate line of investigation is essential has also engendered disagreement among the federal courts. The Supreme Court held that although evidence was discovered as a result of unlawful police conduct, it should not be excluded if it was inevitable the evidence would have been discovered through lawful conduct. In Nix, officers arrested Williams on suspicion of murdering a child. While he was being transported to jail, an officer unlawfully obtained statements from him that led to the discovery of the child's body. At the time, a massive search was underway in the area where the body was located which would have inevitably led to discovery of the body absent Williams's statements. The court excluded Williams's statements but admitted evidence the body was found. (Id. at p. 431.) The Supreme Court decided discovery of the victim's body was inevitable and independent of an unlawful interrogation of the defendant. The court relied on the inevitable discovery exception to the exclusionary rule. ( Id. at pp. 444, 449-450 a search party searching all buildings and culverts was approaching the culvert where the body was found when Williams took officers to the site after being questioned in violation of his right to counsel.) The court discussed an analogous exception, discovery of the evidence by an independent source following a constitutional violation. ( Id. at p. 443.) The Court also held that evidence obtained in violation of the constitution could still be admitted at trial if the prosecution established by a preponderance of the evidence that the information ultimately or inevitably would have been discovered by lawful means. Nix, supra, 467 U.S. at 444; People v. Stevens (After Remand), 460 Mich. 626, 637; 597 N.W.2d 53 (1999). The purpose of the inevitable discovery doctrine is to block setting aside convictions that would have been obtained without police misconduct. Nix, supra, 467 U.S. at 443, n.4.