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.
All labels observed (1)
| Label | Occurrences |
|---|---|
| United States v. Henry canonical | 3 |
How this entity was disambiguated
This entity first appeared as the object of triple T9799113 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: United States v. Henry Context triple: [Massiah v. United States, relatedTo, United States v. Henry]
-
A.
United States v. Eichman
United States v. Eichman is a 1990 U.S. Supreme Court case that struck down a federal law banning flag desecration as unconstitutional under the First Amendment’s protection of free speech.
-
B.
United States v. Bajakajian
United States v. Bajakajian is a 1998 U.S. Supreme Court case that held, for the first time, that a criminal forfeiture could violate the Eighth Amendment’s Excessive Fines Clause if it is grossly disproportionate to the gravity of the offense.
-
C.
United States v. Gratiot
United States v. Gratiot is an 1840 U.S. Supreme Court case that upheld broad federal authority over public lands under the Constitution’s Property Clause.
-
D.
Yates v. United States
Yates v. United States is a 1957 U.S. Supreme Court decision that significantly narrowed the application of the Smith Act by distinguishing between the advocacy of abstract doctrine and the advocacy of concrete action to overthrow the government.
-
E.
Dennis v. United States
Dennis v. United States is a landmark 1951 U.S. Supreme Court decision that upheld the convictions of Communist Party leaders under the Smith Act, significantly shaping First Amendment jurisprudence on speech advocating the overthrow of the government.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: United States v. Henry Target entity description: 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.
-
A.
United States v. Eichman
United States v. Eichman is a 1990 U.S. Supreme Court case that struck down a federal law banning flag desecration as unconstitutional under the First Amendment’s protection of free speech.
-
B.
United States v. Bajakajian
United States v. Bajakajian is a 1998 U.S. Supreme Court case that held, for the first time, that a criminal forfeiture could violate the Eighth Amendment’s Excessive Fines Clause if it is grossly disproportionate to the gravity of the offense.
-
C.
United States v. Gratiot
United States v. Gratiot is an 1840 U.S. Supreme Court case that upheld broad federal authority over public lands under the Constitution’s Property Clause.
-
D.
Yates v. United States
Yates v. United States is a 1957 U.S. Supreme Court decision that significantly narrowed the application of the Smith Act by distinguishing between the advocacy of abstract doctrine and the advocacy of concrete action to overthrow the government.
-
E.
Dennis v. United States
Dennis v. United States is a landmark 1951 U.S. Supreme Court decision that upheld the convictions of Communist Party leaders under the Smith Act, significantly shaping First Amendment jurisprudence on speech advocating the overthrow of the government.
- F. None of above. chosen
Statements (39)
| Predicate | Object |
|---|---|
| instanceOf |
Sixth Amendment case
ⓘ
U.S. Supreme Court case ⓘ criminal procedure case ⓘ |
| appliesDoctrine | Massiah doctrine ⓘ |
| areaOfLaw |
constitutional criminal procedure
ⓘ
evidence law ⓘ |
| citation | 447 U.S. 264 ⓘ |
| constitutionalProvision |
Sixth Amendment to the United States Constitution
ⓘ
linked to:
U.S. Constitution, Sixth Amendment
|
| country |
United States
ⓘ
linked to:
United States of America
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1980 ⓘ |
| fullCaseName | United States v. Henry ⓘ |
| 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 ⓘ |
| language | English opinion ⓘ |
| legalIssue |
deliberate elicitation of incriminating statements
ⓘ
right to counsel ⓘ use of jailhouse informants ⓘ |
| majorityOpinionBy | Potter Stewart ⓘ |
| page | 264 ⓘ |
| precedent | Massiah v. United States ⓘ |
| relatedCase |
Brewer v. Williams
ⓘ
Massiah v. United States ⓘ |
| 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 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: United States v. Henry Description of subject: 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.
Referenced by (3)
Full triples — surface form annotated when it differs from this entity's canonical label.