Hampton v. United States

1976-04-27

Headline: Court upholds conviction of a man who sold heroin supplied by a government informant, ruling government-provided contraband does not bar conviction when the seller was predisposed, limiting due process protection for such setups.

Holding: The Court affirmed the conviction, holding that supplying contraband by a government informant does not violate due process or entrapment rules when the defendant was predisposed to sell the narcotic.

Real World Impact:

Allows convictions when defendants sell contraband supplied by government informants if predisposed.
Limits defendants’ ability to use due process to challenge undercover supply of narcotics.
Gives prosecutors more flexibility in undercover drug investigations.

Topics: undercover police tactics, entrapment, drug crimes, due process limits

Summary

Background

Charles Hampton, a man in St. Louis, was tried for two sales of heroin to people he believed were buyers but who were actually DEA agents. Those meetings were arranged by Hutton, a pool‑playing acquaintance who was working as a government informant. At trial Hampton said he thought the substance was a fake drug supplied by Hutton; the jury convicted him of selling heroin and he was sentenced. Hampton asked the jury to be told he must be acquitted if the narcotics were supplied by a government informant.

Reasoning

The main question was whether a defendant can be convicted for selling contraband that a government informant supplied. The majority said yes: the law’s entrapment defense looks at whether the seller was already willing to commit the crime (his predisposition). Because the record showed Hampton was predisposed to sell drugs, the Court followed its earlier decision in United States v. Russell and held entrapment and due process did not bar conviction here.

Real world impact

The ruling lets prosecutors and undercover agents continue sting operations where informants provide drugs, so long as the government can show the seller was predisposed to deal. The decision does not say government conduct can never be unconstitutional, but it makes successful challenges harder when predisposition is proven. This is not necessarily a final rule for every factual situation; the Court left open very rare circumstances where government behavior might be so outrageous that other protections could apply.

Dissents or concurrances

A concurring Justice agreed with the outcome but warned against a blanket rule, while dissenting Justices argued supplying contraband can be so abusive that convictions should be barred in some cases.