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Law School Case Brief

Hoffa v. United States - 385 U.S. 293, 87 S. Ct. 408 (1966)

Rule:

In the context of the Fourth Amendment, the risk of being overheard by an eavesdropper or betrayed by an informer or deceived as to the identity of one with whom one deals is probably inherent in the conditions of human society. It is the kind of risk we necessarily assume whenever we speak. A secret government informer is not more free from all relevant constitutional restrictions than is any other government agent. The use of secret informers is not per se unconstitutional.

Facts:

The defendants, who were labor union president Hoffa and union members were tried in a federal court in Tennessee on charges of endeavoring to bribe or influence jurors in an earlier trial against Hoffa on a charge of having violated a provision of the Taft-Hartley Act, 18 U.S.C. § 1503. A substantial element in the government's proof in the trial of the present bribery case was contributed by a paid informer, who testified to several incriminating statements made by Hoffa and another defendant in the informer's presence during the course of the earlier trial, when the informer, a Louisiana local union officer under state and federal indictments, but released from jail on bail, made repeated visits to the place of the trial, frequented the Hoffa hotel suite, also used as conference room by Hoffa's counsel, and made frequent reports to a federal agent concerning the conversations in which the incriminating statements were made. After completion of the first trial, the informer's wife received payments from government funds, and the state and federal charges against the informer were either dropped or not actively pursued. In the present bribery prosecution, the trial court denied a motion to suppress the informer's evidence. The defendants were convicted, and the convictions were affirmed by the United States Court of Appeals for the Sixth Circuit. Petitioner defendants sought a writ of certiorari.

Issue:

Did evidence obtained by the Government by means of deceptively placing a secret informer in the presence of defendant labor union president Hoffa during a criminal trial violate defendant's Fourth, Fifth and Sixth Amendment rights such that suppression of that evidence was required in a subsequent trial of the same defendant on a different charge?

Answer:

No

Conclusion:

The grant of certiorari was limited to the single issue of whether the Government's use in this case of evidence supplied by the informant operated to invalidate these conviction. The Supreme Court of the United States affirmed the convictions because defendant Hoffa had no interest legitimately protected by the Fourth Amendment in the hotel room where the informant overheard the information. Hoffa was not relying on the room's security, but rather on his misplaced confidence in the informant. The rights of Hoffa under the Fifth Amendment were not violated because there was no coercion involved in his conversations with the informant. The Sixth Amendment right to counsel was not violated by the informant's presence in room where he conferred with his lawyer because none of the incriminating statements heard were made in the presence of counsel. Finally, Hoffa had no right under the Sixth Amendment to be arrested as soon as the slightest probable cause was established.

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