## Facts

- James R. Hoffa was tried in federal court in Nashville, Tennessee, on a Taft-Hartley Act charge (the “Test Fleet” trial); the jury failed to reach a verdict.
- During that trial, Edward Partin, a paid government informant, spent substantial time with Hoffa in Hoffa’s hotel suite, the hotel lobby, and other locations.
- According to Partin, Hoffa and others made incriminating statements in Partin’s presence about efforts to influence or bribe jurors in the Test Fleet trial.
- In 1964, Hoffa and codefendants were tried and convicted under 18 U.S.C. § 1503 for corruptly endeavoring to influence and bribe jurors connected to the Test Fleet trial.
- The defendants challenged the government’s use of Partin and sought to suppress the evidence derived from his presence and testimony.

## Issues

1. Whether the government’s use of a secret informant invited into Hoffa’s hotel suite and confidences constituted an unreasonable search or seizure under the Fourth Amendment.
2. Whether admitting Hoffa’s statements to an informant violated the Fifth Amendment privilege against compelled self-incrimination.
3. Whether the informant’s presence during an ongoing, separate criminal trial violated the Sixth Amendment right to counsel or otherwise required suppression in a later prosecution.
4. Whether the use of a covert informant in these circumstances violated due process.

## Decision

- The Supreme Court affirmed the convictions.
- The Court held there was no Fourth Amendment violation because Hoffa voluntarily spoke in the presence of a person he invited and assumed the risk that the listener would disclose the information to the government.
- The Court held there was no Fifth Amendment violation because the statements were voluntary and not the product of governmental compulsion.
- The Court held there was no Sixth Amendment violation because the challenged conviction was for a separate offense, and the admitted statements were not shown to intrude upon attorney-client communications or legitimate defense preparation for the earlier trial.
- The Court held the use of an informant was not categorically unconstitutional and did not deny due process where the informant’s credibility was tested through cross-examination and jury instructions.

## Legal Principles

- The Fourth Amendment does not protect a defendant from the risk that an invited confidant is a government informant; voluntary disclosures to such a person are not treated as a governmental search.
- The Fifth Amendment self-incrimination clause bars compelled statements, not voluntary conversations with an informant outside custodial interrogation or other coercive settings.
- The Sixth Amendment is implicated by governmental intrusion into attorney-client communications or defense strategy for the charged offense; it is not violated merely because an informant hears a defendant’s out-of-court statements unrelated to counsel communications, especially when used to prove a different offense.
- Law enforcement is not required to arrest immediately upon probable cause if officers choose to continue investigating.
- Informant use is subject to ordinary trial safeguards (cross-examination and credibility instructions), and is not, by itself, a due process violation.

## Conclusion

The Court upheld convictions for endeavoring to bribe jurors, ruling that voluntary statements made to an invited associate who secretly cooperated with the government could be admitted without violating the Fourth, Fifth, or Sixth Amendments, and that the informant’s use did not render the proceedings fundamentally unfair.


Hoffa v. United States, 385 U.S. 293 (1966)