Identification of the parties
In this court case, Robert William is the defendant while Brewer is the complainant. William was arraigned on a crime of abducting a 10-year girl after he runs away from a mental hospital. When William and the cops were driving between Davenport and Des Moines in Iowa, the officer interrogated William in the absence of his lawyer. The police convinced William to show the directions of the body of the girl.
The case was argued on 4th October 1976 at Iowa Supreme Court and decided on 23rd March 1977. An appeal was granted at Federal District Court.
Facts of the Case
Robert William had recently run away from a mental hospital, and he was a suspect of kidnapping a 10-year old girl called Pamela Powers on 24th December 1968. He had abducted the girl from YMCA in Des Moines where the child and her family were watching her brother who was participating in a wrestling tournament. The girl had gone to the washroom, but she did not come back which lead to her search to commence. A young boy who gave him a hand in putting a large package that was wrapped using a blanket saw two legs that were white and skinny. His warrant for arrest was issued by a Des Moines, police officer. It was exactly two days after the kidnapping that William consulted an attorney at De Moines who requested him not to answer any question from the police. The defendant was arrested according to the warrant issued for him, and William surrendered himself to the Davenport police. The De Moines defendant lawyer organized for the two cops to arrest William in Davenport. The lawyer urged them not to question William in his absence, and they both agreed. The defendant arraignment took place in Davenport where he had a chance to talk with Davenport lawyer who also advised William not to respond to the police interrogations (The US, pp. 390). He also reiterated to the offices that they were not to ask William any question as they return to Des Moines until he gets his attorney.
One officer convinced William to tell them the direction of the body of the girl using a Christian burial speech. In his speech, the police requested William to have a look at the weather outside which had signs that it will snow. The police told William that if indeed it snows the people will never recover the body of the little girl and therefore, they will never give her a Christian burial (Brewer vs. William, pp.487). The officer knew that since William was a religious man, he will be convinced with his speech. Also, in his testimony, the officer agreed that his speech was to get evidence from the defendant. On their way, the defendant stopped the policed and made incriminating statements, and he also showed them the direction where the body was hidden (The US, pp. 401).
A search was done systematically in the area with the help of two hundred volunteers, but this was stopped when William guided the officers to the childs body. During the trial, the judge deprived of his attempt to deny the evidence as his statement indicated that he was guilty at Iowa Supreme Court (Brewer vs. William, pp.489). The defendant was convicted of first-degree murder. Nevertheless, the defendant had been denied the right to have an attorney when he was speaking to the officer in the vehicle. When all the circumstances to his test are applied, the defendant was denied his counsel right as it was affirmed by the Supreme Court in the United States. The state did not establish that the defendant waived the right to have an attorney present violating the sixth amendment of the constitution.
The facts that lead to appeal
In the Iowa court, the defendant was convicted as guilty of first-degree murder. His lawyer suppressed all the evidence that resulted or related to any information that William made in the car when their ride from Davenport heading to Des Moines. The motion was denied by the judge who was hearing William trial. He found out that there was a covenant between the police officers and defendants lawyer to the point that William was not to be asked anything concerning the matter on their way back to Des Moines. During this questioning, it was very significant that an attorney had to be present (Brewer vs. William, pp.492). According to the ruling made by the judge, the dependents right to counsel was waived. During the lawyer objection to the subsequent trial, the evidence was introduced.
The judge in Iowa court went ahead to convict William of murder even after the evidence that the testimony he made in the ride to Des Moines were against the law since his lawyer was absent at the time of questioning (Brewer vs. William, pp.492). The state could not prove that the defendant voluntarily waived his right to have a lawyer at the time the police was suppressing information from him in their car since they had an agreement. These facts led to William petitioning his case. The defendant made an appeal for the summoning of habeas corpus.
The decision and reasoning of all the appeals courts that reviewed the original verdict
William was granted a petition to the Federal District Court for writ of habeas corpus being that the evidence from the defendants statement that he made in the vehicle that the court admitted was wrong. Counsel presented the appeal for William and the state starting that the case was to be based on the previous records of the proceeding and facts presented in the trial court. No more evidence or statement would be added in the case. The federal court analyzed the findings of the case and made a conclusion that as far as the law is concerned the Iowa law admitted the evidence incorrectly and hence made a wrong decision to Williams case (Brewer vs. William, pp.495), U.S pp. 398). The amendments could not be used at the 2nd trial the only evidence that was admitted is the location of the girls body in the sense that the body would still have been discovered even without the statements that William made.
The state proved that they would have continued with the search till the get the body. During the second trial, the statements he made in the car were not offered as evidence nor did the whole prosecution process try to show that William had shown the officers where the childs body was located. At the second trial, William has convicted again of first-degree murder. There was a reversal by the appeal court holding that the state did not meet the requirements that exempted that the officer was not acting in bad faith when he suppressed information from the defendant (U.S, pp. 397-397).
The final decision of the US Supreme Court
The defendant received the Supreme Court trial. In this proceeding, Williams lawyer came to overpower all evidence stemming from the defendants questioning by police officers. The final decision by the judge was that the respondent's testimony to the police was inadmissible. The judge cited Stewarts annotation and ruled that body of the girl was acceptable as evidence since law enforcements could have discovered it.
On 15th July 1977, Robert William was found guilty of first-degree murder. The Supreme Court upheld this conviction in Nix v. William, 1984. This ruling by the Supreme Court affirmed the constitutionality of an inevitable discovery exception. The final decision that the United States Court made clear what constitutes a waiver as a legal right to a lawyer for the amendment of the 6th constitution (U.S, pp. 398-39).
The ruling by the court declared that William constitutional protections had been denied. The defendant waiver was not voluntary, and the state suppressed information from him. The Supreme Court gave certiorari to reflect the legal issues that were presented following William vs. Brewer case.
Explanation of the rationale (reasoning) of the Court of coming up with its decision
When the Supreme Court gave out its ruling; it based its decisions on three independent and alternative grounds. They include the following;
The defendant had been deprived the representation and assistance of a lawyer who is a constitutional right when the officer interrogated him in the car in the absence of Williams lawyer.
William had been deprived his constitutional protections that are stated by Escobedo vs. Illinois and Miranda V. Arizona a policy made to protect the constitutional rights against enforced self-incrimination.
The defendant, William made self-incriminatory testimonies when they were traveling to Des Moines were involuntarily made. The police told William that he was not questioning them, but he ended up suppressing information from him without his consent (Brewer vs. William, pp.499)
Violation of right to counsel
The defendant had a right to the help of a lawyer that are provided by the 6th and 14th amendments of the constitution. This right was violated in Williams vs. case (U.S, pp. 399).
Judicial proceeding against William started without the consent of the defendant.
The police officer designed and intended to get evidence or information from William by violating the agreement between the officer and the lawyer of the accused which was that no interrogation was to take place in the absence of the defendants lawyer.
The situations in Brewer vs. William provide no realistic foundation for finding that the accused waived his right to assistance of an attorney.
Opposing to the reaction of the state courts, the problem of starting a relinquishment was on trial. Comprehension of a person right is not a waiver since an exemption needs more than just human rights.
The defendant, William implicitly and expressly appealed to his right to an attorney for numerous times.
Cases that this decision on U.S Criminal justice system
The decision of Brewer vs. William case changed the judicial system in U.S where there was an addition of a rule in the court system. William 1 rule guaranteed that the sentence of the accused person would be based on adversarial process rather than expertise investigated by police officers. The police do not interrogate a suspect without his/her lawyer or a prosecutor at the court in U.S.
Texas vs. Cobb case
The right to counsel is a particular offense. If the defendant is accused one offense and he/she have a counsel to represent the defendant, police officers can go ahead and question the defendant in the without his lawyer being present about a different crime for which judicial proceeding have not been started.
Messiah vs. the United States
In this case, the opinion of Messiah in the deterrence of United States from interrogating defendant without counsel was attached to the sixth amendment. The police officer took advantage of William in his speech of Christian burial. It violates the constitutional rights of people.
In conclusion, the state has a great responsibility to ensure that it have verified proof of evidence before coming up with a ruling. Other than just doing a factual finding the state should ensure it does total hypothetical finding so that they could compare them with an independent source. The state requires convincing and clear to justify their proof. Police officers should not interrogate a defendant in the absence of his lawyer since this violates his right.Work Cited
"Brewer v. Williams: What Is Interrogation-When Does It Matter." Geo. LJ 67 (1978): 1.
United States Supreme Court 430 U.S. 387 (1977)
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