## Facts

- A 10-year-old girl disappeared from a YMCA in Des Moines, Iowa; Robert Anthony Williams abducted and killed her and left her body along a rural gravel road.
- Hundreds of officers and volunteers began a coordinated, systematic search organized into teams sweeping areas in a grid pattern.
- Williams surrendered in Davenport, Iowa, was arraigned, and counsel was appointed.
- Police agreed with counsel that they would transport Williams to Des Moines without questioning him during the trip.
- During transport, an officer made an appeal to Williams’s conscience (the “Christian burial speech”); without counsel present, Williams made incriminating statements and directed officers to the body.
- In earlier litigation, Williams’s statements were held obtained in violation of his Sixth Amendment right to counsel and were barred from use at a new trial.
- At Williams’s retrial, the State did not introduce his statements or that he led police to the body, but offered evidence of the body’s location, discovery, and condition (including autopsy results).
- The trial court admitted the physical evidence, finding the ongoing search would have discovered the body within a short time and in essentially the same condition.
- Federal habeas relief was denied in district court; the Eighth Circuit reversed, reasoning the State had not shown an absence of police bad faith.
- The Supreme Court reviewed whether the physical evidence was admissible under an inevitable discovery theory.

## Issues

1. Whether physical evidence derived from a constitutional violation must be excluded when it would have been discovered inevitably by lawful means.
2. What burden of proof governs the State’s showing of inevitable discovery.
3. Whether application of inevitable discovery requires proof that police did not act in bad faith.

## Decision

- The Court held the evidence concerning the body’s discovery, location, and condition was admissible under an inevitable discovery exception to the exclusionary rule.
- The Court adopted inevitable discovery as a limit on “fruit of the poisonous tree”: evidence is not excluded if it would have been found through lawful procedures.
- The prosecution must prove inevitable discovery by a preponderance of the evidence, not by speculation.
- The Court rejected any separate requirement that the State prove officers acted in good faith or lacked bad faith.
- On the record, the Court concluded the volunteer search teams were already approaching the body’s location and would have found it shortly had the search continued.

## Legal Principles

- The exclusionary rule is a judicially created deterrent remedy; it aims to place the government in the same position it would have occupied absent misconduct, not a worse one.
- Under inevitable discovery, evidence obtained through unlawful means is admissible if the State proves by a preponderance of the evidence that the evidence would inevitably have been discovered through lawful investigative efforts already in progress.
- Inevitable discovery does not require a subjective inquiry into officers’ good faith or bad faith.
- The doctrine requires a concrete showing that lawful procedures would have led to the evidence, not post hoc conjecture.

## Conclusion

The Court affirmed admission of evidence about the victim’s body because an active, organized search would have found it in short order, and it formally recognized inevitable discovery as an exception to exclusion when the State proves inevitability by a preponderance of the evidence without any additional bad-faith limitation.


Nix v. Williams, 467 U.S. 431 (1984)