In United States v. Morrison (1981) 449 U.S. 361, agents knew the defendant had retained counsel; nonetheless, they contacted her, without her attorney's knowledge, in an attempt to obtain her cooperation in a related investigation. (Id. at p. 362.) The agents disparaged the defendant's attorney, said the defendant would be better off represented by the public defender, and told her she would gain benefits by cooperating but would face a "stiff jail term" if she did not. (Ibid.) Her counsel moved to dismiss the indictment with prejudice because of governmental interference with the defendant's Sixth Amendment right to counsel. (Id. at p. 363.) The sole basis for the motion to dismiss was "the egregious behavior of the agents," which "'interfered' in some unspecified way with the defendant's right to counsel." (Ibid.) Recognizing that the behavior of the agents was "egregious," the Supreme Court denied relief, observing that, "absent demonstrable prejudice, or substantial threat thereof, dismissal of the indictment is plainly inappropriate, even though the violation may have been deliberate." (Morrison, supra, 449 U.S. at pp. 365-367.) The Supreme Court assumed that law enforcement agents had violated the defendant's Sixth Amendment right to counsel. The court nonetheless held that the defendant was not entitled to dismissal of the indictment because she had "demonstrated no prejudice of any kind, either transitory or permanent, to the ability of her counsel to provide adequate representation in these criminal proceedings." (Id. at p. 366.)