Hendricks v. United States

Background

A man convicted for persuading another to lie under oath (subornation of perjury) appealed after his conviction and sentence. The indictment charged that he caused George W. Hawk to give false testimony before a federal grand jury that was investigating crimes involving public lands and unlawful fencing. The defendant argued the indictment failed to tell him what specific matter was under investigation, so it violated his Sixth Amendment right to know the charges against him.

Reasoning

The central question was whether the indictment’s description of the grand jury’s inquiry gave the defendant enough information about the nature and cause of the accusation. The Court reviewed the indictment language that identified a grand jury “inquiring into certain criminal violations … relating to the public lands and the disposal of the same, and the unlawful fencing thereof,” and relied on earlier decisions. The Court concluded that a general description of the investigation was sufficient. It said it was not necessary to name every particular matter or to spell out exactly how the alleged false testimony became material. Because existing precedents controlled, the Court found the Sixth Amendment claim frivolous and refused to disturb the conviction.

Real world impact

This ruling means indictments that identify the grand jury investigation in general terms can be adequate notice for perjury or subornation charges. The Court dismissed the defendant’s writ of error, leaving his conviction in place. The decision follows prior cases rather than creating a new rule.