Nix v. Williams

Following is the case brief for Nix v. Williams, 467 U.S. 431 (1984)

Case Summary of Nix v. Williams:

  • Williams was convicted of murder.  The U.S. Supreme Court reversed the conviction (in Brewer v. Williams) because police elicited from him the location of the victim’s body in violation of his Sixth Amendment rights.
  • Williams was tried and convicted a second time.  The victim’s body was entered into evidence at that trial.  The government used the evidence because, regardless of the fact that Williams led police to the body, it would have inevitably been discovered by the search party that was looking for the body after the crime.
  • On appeal, the state courts affirmed the conviction.  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 U.S. Supreme court reversed the Court of Appeals.  It held that the inevitable discovery doctrine applies, and that the government need not prove an absence of bad faith.

Nix v. Williams Case Brief

Statement of the Facts:

  • The Crime and the “Christian Burial Speech”

On Christmas Eve in 1968, respondent Williams abducted and later murdered a 10-year-old girl in Des Moines, Iowa.  An extensive search for the girl began with the aid of 200 volunteers.  Two days later, Williams turned himself into the Davenport police, and arrangements were made for police to drive Williams from Davenport to Des Moines.

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.  Williams was later charged and convicted of first-degree murder.

  • Brewer v. Williams, 430 U.S. 387 (1977) and Second Trial

On appeal, the U.S. Supreme Court in Brewer v. Williams reversed the conviction.  It held that the “Christian Burial Speech” was interrogation in violation of Williams’s Sixth Amendment rights. Williams was then tried a second time, without the evidence that Williams led police to the victim’s body.  The trial court determined at the second trial that the search party would have found the body within a short time had the search not been suspended.

Procedural History:

  • The jury at the second trial convicted Williams of first-degree murder.  He was sentenced to life in prison.
  • 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.
  • On a habeas petition, the Federal District Court denied the petition, relying on the inevitable discovery rule.
  • 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.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Could 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.


The judgment of the Eighth Circuit Court of Appeals is reversed.

Rule of Law or Legal Principle Applied:

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.

Concurring Opinion (White):

Justice Stevens’s dissent wrongly characterized Detective Leaming as a villain who intentionally engaged in misconduct.  Four members of the Court in Brewer v. Williams thought Leaming did nothing wrong.

Concurring Opinion (Stevens):

Concurring in the judgment only, Justice Stevens believed that the Court’s majority opinion failed to address the clear constitutional violation by Detective Leaming.  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.

Dissenting Opinion (Brennan):

There is a distinction between the “independent source” doctrine and the “inevitable discovery” doctrine.  The distinction is that under the “independent source” doctrine the evidence was actually discovered through another lawful source.  By contrast, “inevitable discovery” assumes that the evidence would have been discovered through another lawful source if investigation (outside of any constitutional violations) was allowed to occur.  Because of that important distinction, the government should be required to prove the inevitable discovery by a heightened standard — clear and convincing evidence.


Nix v. Williams solidified the application of the inevitable discovery doctrine as an exception to the exclusionary rule in criminal cases.  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.

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