Nix v. Williams
Citation: 467 U.S. 431 (1984)
Facts
Robert Williams was arrested for the murder of a 10-year-old girl. During transport, a detective delivered the famous “Christian burial speech” — urging Williams to tell where the body was so the family could have a Christian burial — eliciting incriminating statements and leading police to the victim’s body. The Sixth Amendment violation (deliberate elicitation without counsel) was conceded. The question was whether the body itself was admissible.
Issue
Should evidence discovered as a direct result of a constitutional violation be admitted if the government can show the evidence would inevitably have been discovered through lawful means?
Holding
Yes. Evidence that would inevitably have been discovered through lawful means independent of the constitutional violation is admissible despite the taint of the violation.
Rule
Inevitable discovery exception to the exclusionary rule: evidence is admissible if the prosecution can prove by a preponderance of the evidence that the evidence would ultimately or inevitably have been discovered by lawful means. No requirement of good faith by police.
Significance
- Companion to Brewer v. Williams (the earlier case that found the Sixth Amendment violation on these same facts)
- Established the inevitable discovery doctrine as an exception to the fruit of the poisonous tree rule (Wong Sun v. United States)
- Distinguished from the independent source doctrine (Murray v. United States): inevitable discovery requires only that discovery would have occurred, not that it did occur through an independent source