Mr. Williams was arrested after being the subject of an investigation into the disappearance of a ten-year-old girl in Des Moines, Iowa. Being named as the lead suspect in an investigation already taking place, Williams was arrested in Davenport, Iowa. Having been Mirandized upon arrest, and having evoked his right to an attorney. His legal counsel was informed he would be transferred back to Des Moines without questioning him. During the transfer of Williams, in which a large-scale search was already in process for the girl, the officer initiating the transfer questioned the subject as to the location of the girls body to avail. Williams told the officer the location of the girls body, and thus incriminating himself while being questioned without his attorney.
The motion to suppress the evidence of Williams incriminating himself was initially denied prior to his Iowa State trial and subsequent conviction. The motion was to suppress the evidence of the body itself, and all subsequent evidence collected from it, including the autopsy. Although the Iowa Supreme Court affirmed Williams’ conviction, and upheld the judgment of the lower court. A second State trial was granted on a Federal habeas corpus appeal, and Williams was again convicted. His appeal to Iowa’s Supreme Court again affirmed the lower court, and added that the evidence was indeed admissible because the large scope of the search effort would inevitably have resulted in the body begin found anyway. The case was appealed to The United States Supreme Court on Constitutional grounds, under writ of Certiorari.
Legal Issues and Questions:
The main legal arguments and questions in this case deal with a person’s Miranda rights, or the rights of the accused in the 5th Amendment, and the admissibility of evidence that was clearly collected illegally to obtain a conviction.
Decision of the Court:
The court affirmed the findings of the Iowa’s court second decision, that the evidence of the body, as well as all subsequent evidence, should be allowed into court based on what they called the “inevitable discovery doctrine”; the evidence would have been found with or without the confession of the suspect. Justice Burger wrote the majority opinion, joined by Blackmun, Powell, Rehnquist, and O’Connor. Justices’ White and Stevens wrote concurring opinions.
The main legal provision discussed in the case is the “exclusionary rule”, defined as evidence collected against a suspects’ right to an attorney. The Iowa Supreme Court, as well as the petitioner Mr. Nix, relied on the idea that because the discovery of the body was inevitable, it must be allowed in a trial. Called the “inevitable discovery doctrine”, this apparently trumped what is a clear Fifth Amendment violation–the suspect requested a lawyer, and therefore cannot Constitutionally be questioned without one. This has been established in previous Miranda cases, and by and large this case is reflective of a partisan Court–especially with regards to Blackmun, who was a known originalist. Though it would not be odd for him to write a concurring opinion, for him to join the majority, with Rehnquist as well, is a case that was clearly decided on heartstrings, and not Constitutional interpretation. This is clearly obvious when considering the well-known views of the individual Justices.