United States v. Carona

After county sheriff Carona (defendant) accepted bribes from Haidl, Haidl became a government informant and secretly recorded meetings with Carona at prosecutors' direction, even though prosecutors knew Carona was represented by counsel; when initial meetings yielded little useful evidence, prosecutors supplied Haidl with fabricated subpoena documents to provoke incriminating statements, and Carona made such statements after Haidl confronted him with the fictitious papers. The district court found the prosecution's conduct violated California ethics rules but refused to suppress the resulting statements, and Carona appealed that suppression ruling.