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Hampton v. United States

(1976)

Supreme Court of the United States - 425 U.S. 484

tl;dr:

Congress can delegate its power of setting tariff rates to executive branch officers as long as Congress provides clear direction and doesn’t give the President sole discretion over the power.

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ICRAIssue, Conclusion, Rule, Analysis for Hampton v. United States

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Facts & HoldingHampton v. United States case brief facts & holding

Facts:The Tariff Act authorized the President to appoint a Tariff...

Holding:Holding (Taft): As a practical matter, Congress must employ executive...

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Hampton v. United States | Case Brief DeepDive
Majority opinion, author: Mr. Justice Kehnquist
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The petitioner was convicted of distributing heroin to undercover agents and claimed entrapment as a defense. However, the Court of Appeals rejected this argument, citing the Supreme Court's ruling that entrapment is not available when a government agent supplies a necessary ingredient in the manufacture of an illicit drug. The defense of entrapment focuses on the defendant's intent or predisposition to commit the crime, not the conduct of the government's agents. The petitioner's due process rights were not violated, as the police conduct did not violate any of the defendant's constitutional rights. The decision is affirmed.

Opinion (Concurrence), author: Mr. Justice Powell
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The legal case involves Charles Hampton's argument that the government's act of supplying contraband to someone who was later charged for trafficking in contraband violated due process. The court held that due process does not necessarily prohibit the use of such investigative techniques. The plurality opinion established a per se rule that due process would never prevent the conviction of a predisposed defendant, regardless of the outrageousness of police behavior. However, the dissenting opinion suggests that an analysis other than one limited to predisposition may be appropriate under due process principles in certain circumstances, particularly those outside the realm of contraband offenses. Justice Powell concurred with the court's judgment but disagreed with the plurality opinion as it delved into issues not brought before the court.

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Dissenting opinion, author: MR. Justice Brennan
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Justice Brennan, supported by Justices Stewart and Marshall, believes that courts should not convict an entrapped defendant, even if they admit guilt, because the methods used by the government to secure a conviction are unacceptable. The author advocates for a focus on whether the police conduct falls below acceptable standards for the proper use of governmental power, and that the trial judge, not the jury, must determine the lawfulness of the government's conduct. The author believes that the police conduct alleged in this case would constitute entrapment as a matter of law, and that reversal of the petitioner's conviction is necessary. The author also agrees with Justice Powell that a bar to conviction can be imposed based on supervisory power or due process principles if the conduct of law enforcement authorities is sufficiently offensive, even if the individuals are predisposed to the crime. The author believes that the police activity in this case was beyond permissible limits and that two significant facts distinguish this case from Russell.

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