Nix v. Williams

In 1968, a 10-year-old girl was abducted from an Iowa YMCA by Robert Williams (defendant). Two hundred people divided into search teams to search the area where police believed the girl could be; the searchers were instructed to search all roads, ditches, and abandoned buildings where the girl's body could possibly be hidden. Williams hired an attorney and surrendered to police. After his arraignment, Williams was transported to Des Moines. Police told Williams’s attorney that he would not be questioned. During transport, one of the officers urged Williams to lead them to the body. Specifically, the officer told Williams to think about how the girl's parents deserved the right to give their daughter a “Christian burial.” Williams then agreed to lead officers to the body, and they found the girl’s body in a ditch within the search area, just over two miles from the nearest search team. Williams was charged with first-degree murder. At his first trial, Williams moved to suppress the evidence of the body as fruit of an unlawful interrogation. The trial court denied the motion, and a jury convicted Williams. The Iowa Supreme Court affirmed. Williams petitioned the United States District Court for the Southern District of Iowa for a writ of habeas corpus. The court held that the evidence should have been suppressed, and the United States Court of Appeals for the Eighth Circuit affirmed. The United States Supreme Court granted certiorari and affirmed. During Williams’s second trial, the prosecution did not offer evidence of the interrogation but did present evidence of the condition of the body. The trial court admitted the evidence, finding that the prosecution had shown by a preponderance of the evidence that the body would have been discovered without Williams’s help. Williams was convicted by a jury and sentenced to life in prison. The Iowa Supreme Court affirmed. Williams again sought a writ of habeas corpus in federal district court. The district court denied Williams’s petition, but the Eighth Circuit reversed. The United States Supreme Court granted certiorari.