Nix v. Williams

Inevitable Discovery Rule

Supreme Court ruling that improperly obtained evidence can be used when it would later have been inevitably discovered by the police

Fruit of the Poisonous Tree Doctrine

Evidence that is derived from an illegal search or interrogation is inadmissible

Situation

Nix was arrested for the murder of a young girl after he responded to police requests for information and made statements that helped the police find the body. Nix was only read his Miranda Rights after he was arrested.

Question

Should illegally obtained evidence be excluded from trial if the state can prove that it would have found the evidence through independent means?

Decision

The evidence should not be excluded because of the "inevitable discovery doctrine," which held that the exclusionary rule did not apply to the child's body as evidence since it was clear that the volunteer search teams would have discovered the body even absent Williams's statements.

Dissent

The inevitable discovery rule relies on a hypothetical situation where police find the evidence. If this doctrine is applied, the police must offer clear and supportive evidence that they would have found the evidence before concluding