385 U.S. 293 (1966)
Issue
The main concern raised by the current case was whether evidence gotten by the government through deceptive placement of a secret informer in the councils and quarters of a defendant in the event of a criminal trial accrues as a criminal act. In fact, the main issue was whether such an act infringes on a defendant’s rights as enshrined in the Fourth, Fifth and Sixth Amendments. As connoted by these amendments suppression of evidence obtained under such circumstances is only allowed in subsequent trials of the same defendant, but on a varying charge (Osteburg & Ward 10).
Ruling
The Judgement was affirmed.
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Analysis
The appellants were indicated and tried for violation a provision contained in the Taft-Hartley Act. Worth noting is the fact that this act monitors activities carried out by labour unions. The trial resulted in a hung jury. Later on, the petitioners comprising of James Hoffa, Larry Campbell, Thomas Parks, and Ewing King were tried and imprisoned in a federal district court. The reason for their conviction aligned with their attempt to bribe jury members. Their conviction was reinforced by testament from a paid government informant; Edward Partin. The informant gave a series of implicating testimonials made by King and Hoffa in his presence in the course of the initial jury trial. Following the verdict, the petitioners made an appeal at the United States Supreme Court arguing that the government informant; Partin conducted an illegitimate search in that he did not disclose his role as a government informant; hence, the need to exclude Partin’s testimony (Casenote Legal Briefs: Keyed to Weaver, Abramson, Bacigal, Burkoff, Hancock, and Lively's Criminal Procedure, Second Edition 19).
Over the appellant’s objection, the Supreme Court granted them a certiorari on the premise that use of evidence supplied by Partin rendered the petitioner’s conviction invalid because it violated their rights as enshrined by the Fourth, Fifth, and Sixth amendments. However, the Supreme Court found that with regards to the Fourth Amendment, the appellant’s rights were not violated by the mere fact that Partin concealed his identity as a government informer. Precisely, Hoffa’s confession of incriminating evidence in Partin’s presence did not rely in the security of the place (hotel room) where he made the confessions (Casenote Legal Briefs: Keyed to Weaver, Abramson, Bacigal, Burkoff, Hancock, and Lively's Criminal Procedure, Second Edition 67). Instead, the confessions relied on Hoffa’s misplaced assurance that Partin would keep secret his wrongdoing.
In line with rights enshrined in the Fifth Amendment, the appellant’s rights were not infringed in that Hoffa’s talk with the government informant were voluntary; hence, did not encompass any rights against obligatory self-incrimination, which are covered by the Fifth Amendment (Osteburg & Ward 24). On a similar note, there Supreme Court’s counsel ruled out any violation of the Sixth Amendment. Worth noting is the fact that violation of Sixth Amendment rights emanating from Partin’s reporting Hoffa’s counsel activities aligned with Taft-Hartley trial to the government might have invalidated the conviction. However, conviction resulting from the consequent trial for a different offense of attempting to bribe jurors would not have rendered the conviction invalid. This is because Hoffa’s incriminating confessions were not made in counsel’s presence, but were only made in Partin’s presence.
Conclusion:
Work Cited
Casenote Legal Briefs: Keyed to Weaver, Abramson, Bacigal, Burkoff, Hancock, and Lively's Criminal Procedure, Second Edition. New York: Aspen Publishers, 2005. Print.
Osteburg, James, & Ward, Richard. Criminal Investigation: A Method of Reconstructing the Past. Boston: Routledge, 2014. Print.
