inevitable discovery rule

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In criminal procedure, the inevitable-discovery rule allows evidence that would otherwise be subject to suppression be admissible if the State can show that the evidence would have been inevitably and legally discovered by lawful means. 

The dictating case on the inevitable-discovery rule is Nix v. Williams, 467 U.S. 431 (1984), in which the Supreme Court upheld the application of the inevitable discovery exception to the exclusionary rule. In that case, the defendant had made admissions of the location of his deceased victim as a response to the police's pleading. However, the admissions were made without the presence of counsel, and when the police eventually found the victim, the defendant was found guilty of first-degree murder. The defendant moved to have the evidence suppressed on the grounds that the admission violated his Sixth Amendment right to counsel

Nonetheless, the Supreme Court held that the inevitable-discovery rule could be applied because the victim would have been found on the same day anyway, given that the exact location was only two and a half miles from where police were searching and in the direction that the search was approaching.  The Court also reasoned that the exclusionary rule was meant to act as a deterrent for unlawful police conduct in obtaining evidence. However, the inevitable-discovery rule would not violate this purpose. 

On the other hand, courts like the Supreme Court of Florida have held that the inevitable-discovery rule is not meant to facilitate warrantless searches. Indeed, where evidence had been obtained through a warrantless search of a defendant's home, the rule may only be applied if the prosecution can show that the police were in the process of obtaining a warrant for the same premises anyway.

[Last updated in May of 2022 by the Wex Definitions Team]