The document provides a case brief on Nix v. Williams, a Supreme Court case addressing the Sixth Amendment right to counsel. The court ruled that evidence can be admissible even if obtained from illegally obtained statements if it can be proven that the evidence would have been discovered inevitably. The decision emphasizes the balance between deterring unlawful police conduct and ensuring juries receive relevant evidence.

1. Case Brief Example
This is an example of a well-written case brief. Note the
compliance with the required format and how the student gets
right to the important points in plain language. If legal terms
are encounter which are not understood, chances are that other
students will not understand them, so it is best not to use them
unless defined within the brief.
Assignment sub-heading: Sixth Amendment Right to Counsel
TITLE AND CITATION
:
Nix v. Williams
, 467 U.S. 431, 104 S.Ct. 2501 (1984)
TYPE OF ACTION
: Review by the U.S. Supreme Court of a lower court ruling that
evidence should be suppressed as a result of a violation of the
Sixth Amendment right to counsel. The state (Nix) sought to
overturn the motion to suppress that was upheld by the U.S.
District Court of Appeals.
FACTS OF THE CASE
:
On December 24, 1968, ten year old Pamela Powers was
kidnapped from an Iowa YMCA and her body was later found in
a ditch, which was within an extensive area that was being

2. searched by volunteers and law enforcement. The defendant was
observed “carrying a large bundle wrapped in a blanket…two
legs in it and they were skinny and white.” Williams’ car, which
contained clothing items belonging to the victim, was found the
next day approximately 160 miles from the incident. Based on
this information, an extensive search was started that extended
from Des Moines to Davenport, Iowa.
Law enforcement obtained a warrant for Williams’ arrest, and
he subsequently turned himself into the authorities in
Davenport. Williams was arraigned and had obtained and
spoken with an attorney. Des Moines police detectives agreed to
transport Williams and not interview him during the drive
between Davenport and Des Moines. During the drive, one of
the detectives on the case began to speak to Williams regarding
the need to find the child’s body before it snowed so that her
parents could give her a proper, “Christian” burial. The
detective did not ask Williams any specific questions during
this conversation. At that point, Williams provided statements
to the detectives that led them to the child’s body.
Williams was then tried in state court and was found guilty of
first degree murder. Williams filed a motion to suppress the
evidence of the body and all related evidence concerning the
body’s location based on illegally obtained testimony. When the
conviction was affirmed by the Iowa state Supreme Court,
Williams sought relief in the U.S. District Court for the
Southern District of Iowa. The U.S. District Court, U.S. Court
of Appeals, and the U.S. Supreme Court agreed with Williams
and determined that he was denied the right to counsel and his
statements, which led to the child’s body, could not be
introduced into evidence.

3. Williams was tried in state court a second time, without the use
by the prosecution of the statements he had given to detectives.
Prosecutors introduced evidence of the child’s body under the
premise of “inevitable discovery”, as the child’s body was in an
area that was within the designated search area. Williams was
convicted a second time and the conviction was upheld by the
Iowa Supreme Court again. Appeals by the parties brought the
case back to the U.S. Supreme Court a second time.
CONTENTIONS OF THE PARTIES:
Nix: The state (Nix) contends that the evidence of the child’s
body and all related evidence concerning the body as to its
location should be admissible in spite of the denial of right to
counsel because the body would have been discovered in any
event due to the wide-ranging search in the area which was not
the result of anything that Williams said to the detectives. In the
second trial, the defendant’s statements were not introduced,
but the body evidence should still be admissible because it
would have been discovered and in the same condition anyway
even if there was no violation of the Sixth Amendment. The
child’s body was found well within the extensive search area
and would have been located by one or more of the over two
hundred searchers nearly the same time that the defendant took
the detectives to the child’s body. This argument is called the
“inevitable discovery rule.”
Williams: Williams contends that were it not for the illegally

4. obtained statements from Williams by law enforcement, the
evidence would not have been discovered or used against the
defendant. The evidence obtained is considered the “fruit of the
poisonous tree,” and therefore should not be admitted at trial.
ISSUE:
Once a violation of the Sixth Amendment right to counsel has
occurred, can evidence obtained from the illegally-obtained
statements be admitted at trial based on the fact that the
evidence would have been discovered anyway?
DECISION:
Yes, because the prosecution was able to prove that the same
physical evidence would have been discovered even if the
constitutional rights violation did not occur.
REASONING:
The court applied the reasoning of the independent source
doctrine to that of inevitable discovery. “The independent
source doctrine teaches us that the interest of society in
deterring unlawful police conduct and the public interest in
having juries receive all probative evidence of a crime are
properly balanced by putting the police in the same, not a
worse, position that they would have been in if no police error
or misconduct had occurred” (quoting from
Nix v. Williams
, 104 S.Ct. 2501, 2509 (1984)).
RULE OF LAW:
Evidence that may have been obtained in violation of a
constitutional protection may still be admissible if it can be

5. proven by a preponderance of the evidence that it was inevitable
that the evidence would have been discovered even if the
violation had not occurred. This is known as the “inevitable
discovery” rule.