Nix v. Williams

467 U.S. 431 (1984)

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Nature of the Case

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Facts

Ten-year-old Pamela disappeared from a YMCA where she had accompanied her parents to watch an athletic contest. D was seen leaving the YMCA carrying a large bundle wrapped in a blanket; a 14-year-old boy who had helped D open his car door reported that he had seen 'two legs in it and they were skinny and white.' A large-scale search was initiated 160 miles from Des Moines as evidence was being discovered at a roadside rest stop. D surrendered to police. D was arrested and arraigned in Davenport, Iowa. D contacted a Des Moines attorney who got another attorney in Davenport to contact D. Police informed the attorney that D would be picked up and returned to Des Moines without questioning. Detective Leaming began a conversation with D talking about the girl and Christmas and how she should be entitled to a Christian burial and how that if it was going to snow, she would never be found. Eventually without any additional prompting D began to relay details of the murder to the detective. D eventually agreed to take the officers to the body. At that time, one search team was only two and one-half miles from where D soon guided Leaming and his party to the body. D was convicted, and the Iowa Supreme Court affirmed, but later federal court habeas corpus proceedings ultimately resulted in the Supreme Court's holding that the police had obtained D's incriminating statements through interrogation in violation of his Sixth Amendment right to counsel. At his second state court trial, his incriminating statements were not offered in evidence, nor did the prosecution seek to show that D had directed the police to the child's body. However, evidence concerning the body's location and condition was admitted, the court having concluded that the State had proved that, if the search had continued, the body would have been discovered within a short time in essentially the same condition as it was actually found. The trial court ruled that if the police had not located the body by D's statement, they would have taken up the search where they had left off and would have found the body very quickly. D was found guilty of first-degree murder and appealed. The Eighth Circuit reversed the denial of habeas relief because they reasoned that the inevitable discovery exception required proof that the police did not act in bad faith. The State has not met that first requirement.