Nix v. Williams

Facts

On December 24, 1968, 10-year-old Pamela Powers disappeared from a YMCA building in Des Moines, Iowa. Williams was seen leaving the building with a large bundle wrapped in a blanket. His car was found the next day in Davenport, Iowa. Some of the child's clothing, some of Williams' clothing, and an army blanket were found at a rest stop near Grinnell. Police thought Williams had left the child or her body somewhere between Des Moines and Grinnell. On December 26, the Iowa Bureau of Criminal Investigation began a large-scale search. Two hundred volunteers, in teams, moved westward from Poweshiek County into Jasper County. They were told to check roads, abandoned farm buildings, ditches, culverts and any other place a small child's body could be hidden. Meanwhile Williams surrendered to police in Davenport and was arraigned. His lawyers were told that the Des Moines police would bring him back without questioning him. During the drive, Detective Learning spoke to him about coming snow and about how the parents should be entitled to a Christian burial for their daughter. Williams then led the officers to the body, which lay next to a culvert in a ditch beside a gravel road in Polk County. The officers in charge had called off the search at 3 p. m. One search team was then only two and one-half miles from the body.

Issues

1. Is evidence of the victim's body and its condition admissible at a second trial under an inevitable discovery exception to the exclusionary rule, where the body would have been found by lawful means even without the police violation?
2. Must the prosecution also prove that the police did not act in bad faith before evidence can be admitted under the inevitable discovery exception?

Holding

The body and its condition were admissible. The State proved by a preponderance of the evidence that the volunteer search would inevitably have found the body in essentially the same condition, and the exception contains no requirement that the police acted in good faith.