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Nix v. Williams: The Case Study


The Nix v. Williams case established an “inevitable discovery,” an exemption to the exclusionary rule, in the United States Supreme Court. As “fruit of the poisonous tree,” most evidence gathered in violation of the Fourth Amendment to the United States Constitution, that protects against arbitrary searches and seizures, is barred in criminal cases (Cole et al., 2018). In the case of Nix v. Williams, the Supreme Court held that evidence that would have been discovered by the police force using permitted means was still admissible.

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Nix v. Williams

Nix v. Williams faced a case of killing a ten-year-old child and were asked to lead the police to the crime scene. The accused provided the police with the details that aided them in locating the ten-year-old’s body (“Nix v. Williams,” 1984). The police had negotiations with him to cooperate and help them find the body. However, the police only read him his Miranda rights after his arrest. This was unconstitutional as he would have been well within his rights if he had chosen not to assist the police. William was unaware that it was his right to remain quiet until a legal representative accompanied him. However, Williams never knew that everything he uttered would be used to convict him in court. There was a claim that the police had received information concerning the body’s location under false pretenses and thus could not introduce that evidence in court. However, the evidence could be utilized because the body would have been found with or without the defendant’s help in locating the body, according to the judgment.

Miranda Rights

In 1966, the Miranda rights were created after the case of Miranda vs. Arizona. There were several incidents of police officers misusing their authority. People were being wrongfully convicted and suspected individuals losing cases in court because they were not able to defend themselves before the system adopted the Miranda rights. Over time, changes have been made to safeguard citizens from false accusations and arrests.

The Miranda law states that it is the right of any suspected individual not to answer any questions and that anything they say can and will be used against them. According to this law, any suspect can remain silent and refuse to answer any questions that they have no desire to answer, or that may incriminate them (“Fifth Amendment Miranda Rights,” n.d.). As a result, when a suspect is arrested, they should be aware of the Miranda rights law. The police should have notified the defendant of the right to be quiet in Williams’s case. Before he gives the evidence, he should have been informed that it will be used against him. As a result, without this understanding, the information he supplies could be considered corrupt because he was unaware it was evidence at the time.

Exclusionary Rule

In the United States, “the exclusionary rule” is a constitutional provision designed to shield suspects from harm. This regulation prohibits the use of illegally attained evidence in a court of law against a man. It grants the defendant freedom on the grounds of unreasonable searches and seizures (“Exclusionary rule,” n.d.). This law was made to prevent government agencies and the police from abusing the constitutional rights of individuals. Therefore, if the defendant provided information and was unaware that silence was an option or did so unwillingly, hence the information was illegally obtained. Williams was not provided with a legal representative and was not aware of his Miranda rights when he offered the policemen information about the whereabouts of the body (“Exclusionary rule,” n.d.). According to this rule, his testimony should never have been viable in a court of law. However, this evidence was presented to a court that held the inevitable discovery ruling; the exclusion rule was found to be invalid.

Fruits of a Poisonous Tree

This is a metaphor that is occasionally utilized in law. It means that if a tree has been poisoned, the fruits will most likely be poisonous as well. It means that if evidence is gathered illegally, the information obtained is erroneous and coerced, and hence it should not be admissible in a court of law. (“Fruits of a Poisonous Tree,” n.d.). A police officer cannot search a house before obtaining a search warrant, and this also applies to an illegally obtained witness.

The exclusionary rule is usually extended using this metaphoric doctrine. There are, however, a few exceptions to these legal rules. First, even if a crime scene discovery is made, the evidence acquired can still be presented in a court of law. The other exemption is that even though the technique of getting evidence is illegal, the evidence may be valid or acceptable if the evidence and the illegal method are sufficiently distant. Because Mr. Williams was tricked into gathering information and it was against his constitutional rights, this meant that the evidence acquired in the case could not stand up in court. In a court of law, however, the evidence was nonetheless utilized against him.

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Inevitable Discovery

The inevitable discovery concept is a legal doctrine in the U.S. It states that evidence collected illegally can still be used in a court of law if the evidence would have been recovered using legal means regardless. If a client gives incriminating information while unaware of their Miranda rights, the information provided may not be admissible as evidence in a court of law (“The Inevitable Discovery,” n.d.). This is because the evidence was taken illegally from the suspected individual, and providing it would be tantamount to asking the suspect to testify against himself. This legal rule, however, is bowed by the inevitable discovery. If the evidence was obtained by the police in any case, the evidence gained could be presented in court. In Nix v. Williams’s case, he had a right to hold on to the information he provided. However, the judge decided that the evidence could be accepted in accordance with the “inevitable rule.” This is because the court determined that the evidence he provided might have been discovered without his help.


Nix v. Williams’s case was one that could be viewed as fair or not. Indeed, the defendant’s information aided the police finding the murdered child and his subsequent arrest. However, because this information was obtained unlawfully and in violation of his fundamental rights, it should not have been admissible in court. The inevitable discovery doctrine nevertheless led to the conviction of the defendant. The jury decided that the body would still be discovered anyway, even without him providing the information. Because of this, the evidence was used against him in court, and he was found guilty of murder.


Cole, G. F., Smith, C. E., & DeJong, C. (2018). Criminal justice in America (9th ed.). Boston, MA: Cengage.

Exclusionary Rule. (n.d.). In Cornell law school legal information institute. Web.

Fifth Amendment Miranda Rights. (n.d.). In Find Law. Web.

Fruits of a Poisonous Tree. (n.d.). In Cornell law school legal information institute. Web.

Nix v. Williams. (1984). In justia US Supreme Court. Web.

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The inevitable discovery exception to the exclusionary rule under the United States. (n.d.). In North Carolina criminal law. Web.

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