From the August 2005 Harpers:
From a footnote to the May 4 decision of the appeals court for the Seventh Circuit in United States v. Darron J. Murphy Sr. Murphy allegedly hit and threatened Pamela Hayden after finding out that she was going to testify against Murphy’s son.
The trial transcript quotes Ms. Hayden as saying Murphy called her a snitch bitch “hoe.” A “hoe,” of course, is a tool used for weeding and gardening. We think the court reporter, unfamiliar with rap music, misunderstood Hayden’s response. We have taken the liberty of changing “hoe” to “ho,” a staple of rap-music vernacular as, for example, when Ludacris raps, “You doin’ ho activities with ho tendencies.”