Fruit of the poisonous tree

Question 1

Utah v. Strieff

Answer 1

Facts
In Utah v. Strieff, the case began with an anonymous tip about narcotics activity at a residence, which led Officer Fackrell to conduct surveillance. Edward Strieff was observed leaving the house and was stopped by Officer Fackrell in a parking lot. The officer, without reasonable suspicion, detained Strieff and requested his identification, which revealed an outstanding arrest warrant for a traffic violation. Strieff was arrested, and during a search incident to the arrest, the officer found methamphetamine and drug paraphernalia. Strieff moved to suppress this evidence, arguing it stemmed from an unlawful investigatory stop. The trial court admitted the evidence, noting the valid arrest warrant as an intervening circumstance and the absence of flagrant misconduct by the officer. The Utah Court of Appeals affirmed, but the Utah Supreme Court reversed, ordering the evidence suppressed.

Issue
The central issue was whether the discovery of a valid arrest warrant during an unconstitutional investigatory stop is an intervening circumstance sufficient to break the causal chain between the illegal stop and the discovery of evidence, thus making the evidence admissible.

Holding
The U.S. Supreme Court held that the evidence obtained from Strieff following his arrest was admissible. The Court found that the discovery of the arrest warrant sufficiently attenuated the connection between the unlawful stop and the evidence seized incident to the arrest.

Question 2

Nix v. Williams

Answer 2

Facts
On December 24, 1968, 10-year-old Pamela Powers disappeared from a YMCA building in Des Moines, Iowa.
Williams was seen leaving the YMCA with a bundle that appeared to contain human legs.
After his arrest, during transport by police without his lawyer present, Williams was indirectly persuaded to reveal the location of Powers’ body through a conversation initiated by Detective Leaming, suggesting that it was crucial to find the body before a snowstorm to allow for a proper burial.
The body was found in a ditch in Polk County, within an area that was being systematically searched by volunteers.
Williams’ first trial included evidence obtained from this discovery, leading to his conviction.
This conviction was later challenged on the grounds that the evidence was obtained through a violation of Williams’ right to counsel.

Issue
The central issue before the Supreme Court was whether evidence pertaining to the discovery and condition of Pamela Powers’ body should be admitted at Williams’ second murder trial, on the ground that the evidence would have been inevitably discovered even without the violation of Williams’ constitutional rights.

Holding
The Supreme Court held that the evidence regarding the discovery and condition of the victim’s body was admissible under the inevitable discovery doctrine.
This doctrine posits that evidence that would have been discovered without any constitutional violations can be admitted into trial.