Monday, November 4, 2013

Nix v. Williams case brief

Nix v. Williams case brief summary
467 U.S. 431 (1984)

CASE SYNOPSIS
The Court granted certiorari to review a decision of United States Court of Appeals for Eighth Circuit granting respondent's habeas corpus petition on the ground that evidence that was the product of unlawful questioning by police was erroneously admitted, even if the State showed the evidence would have been discovered without the constitutional violation, because the State failed to show that the police had acted in good faith.

CASE FACTS
Respondent was found guilty of first-degree murder. He successfully challenged the conviction on the ground that evidence of his incriminating statements, which led the police to the victim's body, should have been excluded because the evidence was the product of unlawful questioning by the police. At his second trial, no such evidence was admitted, but the trial court admitted evidence of the body's location and condition on the theory that the body would have been discovered in any event, even had the incriminating statements not been elicited from respondent. Respondent attacked his state-court conviction by seeking a writ of habeas corpus in federal district court.

DISCUSSION
  • The district court denied the petition, but the appellate court reversed, holding that if there was an inevitable discovery exception to the exclusionary rule, it required proof that the police did not act in bad faith. 
  • The Court held that there was an inevitable discovery exception to the exclusionary rule, but that it included no such "good faith" requirement. 
  • It concluded that the record supported the finding that the victim's body would inevitably have been discovered; and reversed the appellate court decision.
  • Consider this when hiding your bodies.

CONCLUSION
The Court reversed the appellate court decision.



Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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