Law School Case Brief
United States v. Jeter - 775 F.2d 670 (6th Cir. 1985)
The obstruction of justice statute, 18 U.S.C.S. § 1503, specifically forbids the influencing, intimidation, or impeding of any witness, juror, or court official. The statute also contains an omnibus clause, which punishes the general obstruction of the "due administration of justice." The omnibus clause covers whoever corruptly or by threats of force, or by any threatening letter of communication, influences, obstructs, or impedes, or endeavors to influence, obstruct, or impede, the due administration of justice.
While in jail during the spring of 1983, defendant Phillip Ray Jeter apparently gained interest in media coverage of grand jury proceedings surrounding reputed drug dealers James P. Lambert and Arnold Kirkpatrick. Jeter wrote a sympathetic letter to Madden, an associate of Lambert and Kirkpatrick, who had picketed outside a local television station protesting the unfair coverage about alleged illegal drug activities of her friends. In Sept. 1983 Jeter began to visit the apartment of Halsey, a typist for a federal court reporter service. In Oct. 1983, Halsey's employer gave her materials to type involving grand jury testimony from the Lambert investigation, and Halsey gave Jeter carbon papers used in typing those grand jury transcripts. Jeter then shared and delivered the carbon transcripts to Lambert. Jeter was later convicted in federal district court of conspiracy for illicitly obtaining and participating in the distribution of imprinted carbon sheets used in the typing of secret grand jury documents and proceedings, as well as larceny and obstruction of justice. On appeal, Jeter first argued his conviction under 18 U.S.C.S. § 641, the larceny statute, was improper because the carbon paper was not government property of value making § 641 applicable. Jeter also argued 18 U.S.C.S. § 1503 was not applicable as his actions did not fall within the obstruction of justice statute.
Were Jeter's convictions proper?
The appellate court affirmed the convictions. The court ruled that, as to the larceny conviction, "information" could be deemed a thing of value. In addition, as the grand jury information was to be kept secret according to Rule 6(e)(2) of the Federal Rules of Criminal Procedure, the information was valuable. As to the obstruction conviction, the court ruled that the obstruction of justice statute required neither unconstitutionally overbroad or vague application to Jeter's conduct, since he failed to establish that some protected constitutional activity regarding the passing of grand jury information was required to also fall within § 1503 if the statute was construed to prohibit his particular activity. The obstruction of justice statute as applied and construed in Jeter's case passed the constitutional test set out in Broadrick v. Oklahoma in a fashion that also proved its lack of vagueness.
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