Hoffa v. United States

Brief Fact Summary.

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.

Synopsis of Rule of Law.

The conduct “by the Government by means of deceptively placing a secret informer in the quarters and councils of a defendant during one criminal trial [does not] violate 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.”

Facts.

James Hoffa (“Hoffa”) was charged with violating a provision of the Taft-Hartley Act. He was tried in the autumn of 1962 (“the Test Fleet trial”). The Test Fleet trial ended with a hung jury. Hoffa and various others were convicted in 1964 of bribing members of the jury during the Test Fleet trial. The Court of Appeals affirmed the convictions. One of the government’s witnesses, Edward Partin (“Partin”), testified to various statements made to him by Hoffa and another convicted individual named King.
During the Test Fleet trial, Hoffa occupied a three-room suite in a hotel in Nashville. King was a constant companion of Hoffa in the suite. Partin was also often in the hotel during the trial. Also, Hoffa’s attorneys were in the room. During that time, Partin made various reports to a federal agents about conversations “he said Hoffa and King had had with him and with each other, disclosing endeavors to bribe members of the Test Fleet jury.” Federal agents asked Partin to look out for Hoffa attempting to tamper with the Test Fleet jury. After the Test Fleet trial, Partin’s wife received money from the government and all charges against Partin were dropped.

Issue.

“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[?]”

Held.

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 “[i]n 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.