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United States v. Heldt
United States Court of Appeals for the District of Columbia Circuit
668 F.2d 1238 (1981)
Facts
Members of the Church of Scientology (church members) (defendants) were indicted for completed conspiracies and substantive offenses arising from their efforts to destroy documentary evidence linking the church’s founder, L. Ron Hubbard, and his wife, Mary Sue Hubbard, to illegal activities. The church members had attempted to steal evidence in government possession, conspired to obstruct justice, harbored a fugitive, and committed perjury. At trial the church members moved to disqualify the entire staff of the office of the United States Attorney for the District of Columbia on the grounds that the office had a disqualifying emotional interest in the case as one of the “victims” of the alleged crimes, and because one of the attorneys in the office had at one point been employed by a law firm that represented one of the church members. The district court denied this motion. The church members were eventually convicted of some of the charges. On appeal, the church members claimed that the district court erred in refusing to disqualify all of the attorneys in the office. The church members also alleged for the first time that they were denied due process because two prosecutors had been named in a civil action filed by the church in relation to a search of the church’s offices.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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