United States v. Henry

E821208

United States v. Henry is a U.S. Supreme Court decision that further defined the Sixth Amendment right to counsel by limiting the government’s use of jailhouse informants to deliberately elicit incriminating statements from indicted defendants.

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Label Occurrences
United States v. Henry canonical 1

Statements (39)

Predicate Object
instanceOf Sixth Amendment case
U.S. Supreme Court case
criminal procedure case
appliesDoctrine Massiah doctrine NERFINISHED
areaOfLaw constitutional criminal procedure
evidence law
citation 447 U.S. 264
constitutionalProvision Sixth Amendment to the United States Constitution NERFINISHED
country United States of America
surface form: United States
court Supreme Court of the United States
decisionDate 1980
fullCaseName United States v. Henry NERFINISHED
governmentActionChallenged use of paid informant placed in same cellblock as indicted defendant
holding The government may not use a paid jailhouse informant to deliberately elicit incriminating statements from an indicted defendant in the absence of counsel.
The government violates the Sixth Amendment when it intentionally creates a situation likely to induce an indicted defendant to make incriminating statements without counsel present.
impact clarified standards for deliberate elicitation under the Sixth Amendment
limited government use of jailhouse informants after indictment
jurisdiction United States federal law NERFINISHED
language English opinion
legalIssue deliberate elicitation of incriminating statements
right to counsel
use of jailhouse informants
majorityOpinionBy Potter Stewart NERFINISHED
page 264
precedent Massiah v. United States NERFINISHED
relatedCase Brewer v. Williams NERFINISHED
Massiah v. United States NERFINISHED
relatedConcept post-indictment interrogation
right to counsel attachment at indictment
reporter United States Reports
result conviction reversed
ruleOfLaw Once the Sixth Amendment right to counsel has attached, the government may not deliberately elicit incriminating statements from the defendant in the absence of counsel.
stage direct review of criminal conviction
topic criminal defendants’ post-indictment rights
exclusion of evidence
government use of informants
volume 447
vote 6–3
yearDecided 1980s

Referenced by (1)

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Massiah v. United States relatedTo United States v. Henry