Hoffa v. United States
385 U.S. 293 (1966)
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Rule of Law:
The Fourth Amendment does not protect a wrongdoer's misplaced belief that a person to whom they voluntarily confide their wrongdoing will not reveal it. The use of a secret government informant who is invited into a defendant's private space does not constitute an illegal search if the defendant voluntarily makes incriminating statements to, or in the presence of, the informant.
Facts:
- During his 1962 trial in Nashville for a violation of the Taft-Hartley Act (the 'Test Fleet trial'), James Hoffa, president of the Teamsters Union, occupied a three-room hotel suite.
- Edward Partin, a Louisiana Teamsters official facing state and federal criminal charges, was contacted by federal agents and agreed to report any attempts at jury tampering he observed in Nashville.
- Partin contacted Hoffa, claiming to want to discuss union business and his own legal troubles, and arranged to meet Hoffa in Nashville.
- Hoffa invited Partin to his hotel suite, where Partin was a constant companion and was frequently present with Hoffa and his associates.
- While in Hoffa's company at the hotel, courthouse, and other locations, Partin heard Hoffa and his associate, Ewing King, make numerous incriminating statements about their plans and attempts to bribe jurors in the Test Fleet trial.
- Partin regularly reported these conversations to a federal agent, providing information that was later used to prosecute Hoffa for jury tampering.
- Following the Test Fleet trial, the criminal charges against Partin were not actively pursued, and his wife received four monthly payments of $300 from the government.
Procedural Posture:
- James Hoffa and three co-defendants were charged in U.S. District Court with endeavoring to bribe jurors from a previous trial.
- The defendants filed a motion to suppress the testimony of the government's key witness, Edward Partin, which the trial court denied.
- A jury convicted all four petitioners on the jury tampering charges.
- The petitioners appealed their convictions to the U.S. Court of Appeals for the Sixth Circuit.
- The Court of Appeals affirmed the convictions.
- The petitioners filed a petition for a writ of certiorari with the U.S. Supreme Court, which was granted on the limited question of the constitutionality of using evidence supplied by the informer.
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Issue:
Does the government's use of a secret informer to obtain incriminating statements from a defendant, by having the informer gain the defendant's confidence and being invited into his private quarters, violate the defendant's Fourth, Fifth, or Sixth Amendment rights?
Opinions:
Majority - Justice Stewart
No. The use of a secret government informer who obtains incriminating statements by gaining the defendant's trust does not violate the Fourth, Fifth, or Sixth Amendments. The Fourth Amendment does not protect a person's misplaced confidence in an associate. The petitioner was not relying on the security of his hotel room, but rather on his mistaken belief that Partin would not reveal his wrongdoing. Because the incriminating statements were made voluntarily and not as a result of any coercion, the Fifth Amendment right against self-incrimination was not implicated. While Partin's presence in the defense camp during the Test Fleet trial might have raised a Sixth Amendment issue for that trial, the statements used in the subsequent jury tampering trial were not the 'fruit' of any intrusion into attorney-client communications; they were about a separate crime and made outside the presence of counsel. Finally, there is no constitutional right to be arrested, so the government had no duty to charge Hoffa the moment it had probable cause.
Dissenting - Chief Justice Warren
Yes. While not necessarily reaching the specific constitutional amendments, the government's conduct was so offensive to the fair administration of justice that the conviction should be overturned using the Court's supervisory powers. The government reached into a jailhouse to employ an informant, Partin, who was facing his own serious charges and thus had a powerful incentive to fabricate evidence against Hoffa. The government then assisted this 'jailbird' in infiltrating the defense's camp during an active trial, not merely to report on past crimes, but to witness future ones. Allowing a conviction to stand on the testimony of such an unreliable informant, whose services were procured in this manner, undermines the integrity of the federal courts and the truth-finding process.
Analysis:
This case solidifies the 'misplaced confidence' or 'assumption of risk' doctrine in Fourth Amendment jurisprudence. It establishes that what a person knowingly exposes to a third party, even within a constitutionally protected area like a home or hotel room, is not protected from the risk that the third party is a government agent. This decision grants law enforcement significant leeway in using undercover informants to investigate criminal activity without implicating the Fourth Amendment's warrant requirement. It distinguishes between surreptitious electronic surveillance, which constitutes a search, and the risk of betrayal by a trusted confidant, which does not.
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