Tuesday, November 5, 2013

United States v. Havens case brief

United States v. Havens case brief summary
446 U.S. 620 (1980)

CASE SYNOPSIS
Defendant was convicted in a United States district court of various drug offenses. The defendant appealed, and argued that evidence which had been suppressed was improperly introduced to impeach his testimony at trial. The United States Court of Appeals for the Fifth Circuit reversed. The prosecution sought certiorari.

CASE FACTS
Defendant's co-conspirator was searched as he tried to enter the United States, and cocaine was found in pockets sewn into his shirt. Defendant's luggage was then searched, and a tee-shirt with cut out material corresponding to the pockets in the shirt was found. The cut up shirt was suppressed. At trial, the defendant denied any knowledge that the co-conspirator was smuggling drugs. In his direct testimony, the defendant stated he had nothing to do with the co-conspirator's concealment of drugs on his body. On cross-examination, defendant was asked if he had anything to do with sewing the pockets on the co-conspirator's shirt, and defendant denied any participation. The prosecution was then permitted to introduce evidence of the cut up tee-shirt. Defendant appealed and the appellate court reversed the conviction. The prosecution sought certiorari.

HOLDING
The Court held that illegally seized evidence was properly admitted to impeach any aspect of defendant's testimony, and that such impeachment was not limited to a direct contradiction of a particular statement made during direct testimony.

CONCLUSION
The Court reversed the judgment of the appellate court that reversed the defendant's conviction, and remanded for further proceedings consistent with the Court's opinion.



Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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