United States v. John Leon Spencer

This ease requires an examination of the evidence preservation and disclosure requirements mandated by the Jencks Act, 18 U.S.C. § 3500 .

In January 1979 counterfeit hundred dollar bills were passed in Stockton, California. The defendant, John Leon Spencer, became a key suspect in a Secret Service investigation of the counterfeit currency. The agent in charge of that investigation informed the Stockton police that Spencer was believed to be carrying forged bills. Although no warrant had been issued for passing the counterfeit Federal Reserve notes, the agent did inform the police that Spencer was wanted on an unrelated state misdemeanor warrant, and provided the suspect’s work and home addresses.

Acting on this information, Detective Michael Brooks was detailed by the Stockton police to make the arrest. As Spencer climbed down from a truck at his place of employment, he was arrested on the state misdemeanor warrant. The defendant eventually consented to a search of the truck which yielded twenty counterfeit one hundred dollar bills and other contraband. Spencer was tried and convicted of possessing and passing these spurious notes, pursuant to Title 18 U.S.C. § 472 .

At trial…