Hoffa v. United States Case Brief

Why is the case important?

A government informant was in a hotel room with a criminal defendant during a trial. The defendant often conferred with his attorneys in the room. The informant was there in order to obtain information from the defendant to be used during a second trial for witness tampering.

Facts of the case

These are several consolidated cases involving similar circumstances. In the lead case, a district court in Tennessee tried and convicted James Hoffa, the president of a labor union, for attempting to bribe members of a jury in an earlier trial. A paid government informer provided substantial evidence in the bribery trial. The informer was another local union officer who met with Hoffa on several occasions during the first trial. At that time, the government had not hired the officer as an informant. Hoffa alleged that the evidence gathered from this informer violated his Fourth, Fifth and Sixth Amendment rights. The U.S. Court of Appeals for the Sixth Circuit affirmed the conviction.

Question

Whether evidence obtained by the Government by means of deceptively placing a secret informer in the quarters and councils of a defendant during one criminal trial so violates the defendant’s Fourth, Fifth and Sixth Amendment rights that suppression of such evidence is required in a subsequent trial of the same defendant on a different charge?

Answer

“The majority first observed that Partin was a government informant as soon as he arrived in Nashville and that the government compensated him for his services as such.
The majority then observed that a hotel room can clearly be the object of Fourth Amendment protection as much as a home or an office. Further that in the present case, however, it is evident that no interest legitimately protected by the Fourth Amendment is involved. It is obvious that the petitioner was not relying on the security of his hotel suite when he made the incriminating statements to Partin or in Partins’ presence. Partin did not enter the suite by force or by stealth. He was not a surreptitious eavesdropper. Partin was in the suite by invitation and every conversation which he heard was either directed to him or knowingly carried on in his presence. The petitioner, in a word, was not relying on the security of the hotel room

  • he was relying upon his misplaced confidence that Partin would not reveal his wrongdoing. As such, no right protected by the Fourth Amendment was violated.
    Hoffa’s Fifth Amendment claim that he was compelled to be a witness against himself was also without merit. There was no type of compulsion or coercion.
    Hoffa also made two Sixth Amendment arguments found to be without merit. First, Hoffa argued that his lawyers used his suite as a place to confer with him and with each other, to interview witnesses, and to plan the following day’s trial strategy. Accordingly, he argued that Partin’s presence in and around the suite violated the petitioner’s Sixth Amendment right to counsel because an essential ingredient thereof is the right of a defendant and his counsel to prepare for trial without intrusion upon their confidential relationship by an agent of the Government, the defendant’s trial adversary. In discounting this argument, the majority observed it is far from clear to what extent Partin was present at conversations or conferences of the petitioner’s counsel. Also, the majority distinguished two cases by observing Hoffa’s statements related to the commission of a quite separate offense.
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    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.

    • Case Brief: 1966
    • Petitioner: James R. Hoffa
    • Respondent: United States
    • Decided by: Warren Court

    Citation: 385 US 293 (1966)
    Argued: Oct 13, 1966
    Decided: Dec 12, 1966
    Granted Jan 31, 1966