The government tried Adam Samia and Carl Stillwell (and a third codefendant) jointly for the murder of Catherine Lee. The government alleged that Stillwell and Samia had been hired to murder Lee. Upon Stillwell’s arrest, he admitted that he had been in the van with Samia and Lee at the time that Lee was shot. Stillwell told law enforcement that he was only driving the van, however, and that it was Samia who shot Lee.
At their joint trial, the district court allowed the government to introduce Stillwell’s “confession” through the testimony of a government agent. However, the district court held that, to comply with Bruton and its progeny, the agent could not use Samia’s name and must instead refer only to the “another person” that Stillwell said he was with. The district court instructed the jury that Stillwell’s statement could only be considered in relation to Stillwell. But the government was permitted to argue before the jury that Samia was this “other person” who was in the vehicle with Stillwell and who Stillwell identified as having shot Lee.
The Second Circuit affirmed Samia’s conviction, finding that admission of Stillwell’s redacted statement at their joint trial did not violate Samia’s rights under the confrontation clause. The majority interpreted prior Supreme Court precedent as follows: 1) Bruton recognized a “narrow exception” to the presumption that jurors follow a court’s limiting instructions (thus implying that confrontation clause violations, in general, may otherwise be cured by proper limiting instructions); 2) Richardson v. Marsh then declined to extend the narrow Bruton exception to confessions that do not explicitly name the defendant (and that only become incriminating when linked with other evidence); but that 3) Gray v. Maryland later recognized that a redacted confession could still run afoul of the 6A if it is “obviously redacted” and “directly accusatory.”
Thus, the majority held there is a distinction “between confessions that directly implicate a defendant and those that do so indirectly.” Without providing much guidance about how to distinguish between the two going forward, the Supreme Court simply held that the redaction in Samia’s case “was not obviously redacted in a manner resembling the confession in Gray.”
Certiorari to the Second Circuit
Opinion by Thomas, joined by Roberts, Alito, Gorsuch, and Kavanaugh, and joined in part by Barrett
Opinion by Barrett concurring in part and concurring in judgment
Dissenting opinion by Kagan, joined by Sotomayor and Jackson
Dissenting opinion by Jackson
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