Hoffa v. United States

In Hoffa v. United States (1966) 385 U.S. 293, the United States Supreme Court examined whether the Constitution required suppression of evidence which the government obtained "'by means of deceptively placing a secret informer in the quarters and councils of a defendant'" which was then used in a subsequent trial against the defendant. (Hoffa, supra, 385 U.S. at p. 295.) The evidence in Hoffa came from a government informant who had close connections to the defendant James Hoffa. The informant testified at trial he was present when Hoffa and others discussed making bribes to a previous federal jury. (Id. at p. 296.) Hoffa argued, inter alia, his Fourth Amendment rights were violated because the informer failed to disclose his connection to the government, thereby vitiating any consent Hoffa gave for his presence at the locations where the conversations took place. (Id. at p. 300.) Hoffa contended the informer conducted an illegal Fourth Amendment "'search'" for verbal evidence. (Ibid.) The Hoffa court held the defendant had "no interest legitimately protected by the Fourth Amendment" because the informer was invited to the conversations. (Hoffa, supra, 385 U.S. at p. 302.) The informer "was not a surreptitious eavesdropper." (Ibid.) The Hoffa court made it clear that no Fourth Amendment violation occurred because the defendant "was relying upon his misplaced confidence that the informer would not reveal his wrongdoing." (Ibid.) The court further noted it had never "expressed the view that the Fourth Amendment protects a wrongdoer's misplaced belief that a person to whom he voluntarily confides his wrongdoing will not reveal it." (Ibid.)