During the holiday season, a young girl disappeared from Des Moines, Iowa. Police officers arrested the defendant the next day 160 miles away.
After his initial appearance, the officers told the defendant’s attorney they would pick up the defendant and return him to the appropriate district without questioning him. During the return trip one of the officers initiated a conversation with the defendant, which resulted in the defendant stating where the victim’s body was located. As they approached the location, the defendant agreed to take the officers to the child’s body.
At that time, one search team was only two and one-half miles from where the defendant soon guided the officers to the body. The child’s body was found next to a culvert in a ditch beside a gravel road within the search area.
Whether evidence that was about to be discovered through lawful channels must be suppressed if it is discovered through illegal means?
No. The evidence derived from the conversation was admissible as it would have been inevitably discovered.
The Court held that when illegally seized evidence could have been obtained through an independent source and efforts are underway that would lead to that discovery, exclusion of that evidence is not justified. While the independent source exception may not justify the admission of evidence here (as the evidence had been removed and could not be independently discovered), its rationale is wholly consistent with and justifies the adoption of the inevitable discovery exception to the exclusionary rule. Unlawfully obtained evidence is admissible if ultimately or inevitably it would have been discovered by lawful means.
467 U.S. 431, 104 S. Ct. 2501 (1984)