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Thursday, December 5, 2013

Hoffman v. United States case brief

Hoffman v. United States case brief summary
341 U.S. 479 (1951)


CASE SYNOPSIS
The United States Supreme Court granted certiorari to review a decision of the United States Court of Appeals for the Third Circuit, which affirmed defendant's conviction for criminal contempt for the refusal to answer questions before a federal grand jury and rejected defendant's claim that he was entitled to the protection afforded by U.S. Constitutional amendment Vagainst testimonial self-incrimination.

CASE FACTS
Defendant was convicted of criminal contempt for refusing to obey a federal court order requiring him to answer questions asked in a grand jury investigation. The conviction was affirmed by the court of appeals, and the Court granted certiorari. The grand jury was investigating frauds upon the federal government, including violations of the customs, narcotics and internal revenue liquor laws, the White Slave Traffic Act, perjury, bribery, and other federal criminal laws, and conspiracy to commit all such offenses. Defendant refused to answer questions as to his occupation, as to when he had last seen another named individual, and the whereabouts of that individual, on the ground that his answers might tend to incriminate him of a federal offense.


DISCUSSION

  • The Court reversed defendant's conviction, holding that, under all of the circumstances, defendant's concern that answering the questions might subject him to federal criminal liability was reasonable, and defendant was therefore entitled to the protection afforded by U.S. Constitutional Amendment V against testimonial self-incrimination and should not have been held in contempt for failing to answer.

CONCLUSION

The Court reversed defendant's conviction, holding that, under all of the circumstances, defendant had a reasonable concern that answering the questions might subject him to federal criminal liability, and defendant was therefore entitled to the protection afforded by the Fifth Amendment against testimonial self-incrimination and should not have been held in contempt for failing to answer.

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