Richardson v. Marsh
Annotate this Case
481 U.S. 200 (1987)
U.S. Supreme Court
Richardson v. Marsh, 481 U.S. 200 (1987)
Richardson v. Marsh
Argued January 14, 1987
Decided April 21, 1987
481 U.S. 200
Respondent and Benjamin Williams were charged with murder, robbery, and assault. At their joint trial, Williams' confession was admitted over respondent's objection. The confession had been redacted to omit all reference to respondent -- indeed, to omit all indication that anyone other than Williams and a third accomplice participated in the crime. In his confession, Williams described a conversation he had with the third accomplice as they drove to the victims' home, during which the accomplice said that he would have to kill the victims after robbing them. At the time the confession was admitted, the jury was admonished not to use it in any way against respondent. Williams did not testify. Respondent's testimony indicated that she had been in the car with Williams and the third accomplice, but had not heard their conversation. Respondent insisted that she had not intended to rob or kill anyone. Respondent was convicted of felony murder and assault to commit murder, and the Michigan Court of Appeals affirmed. The Federal District Court denied respondent's petition for a writ of habeas corpus, but the Court of Appeals reversed, holding that respondent was entitled to a new trial under Bruton v. United States, 391 U. S. 123. Bruton held that a defendant is deprived of his rights under the Confrontation Clause when his nontestifying codefendant's confession naming him as a participant in the crime is introduced at their joint trial, even if the jury is instructed to consider that confession only against the codefendant. The Court of Appeals held that Bruton requires the same result when the codefendant's confession is redacted to omit any reference to the defendant, but the defendant is nonetheless linked to the confession by evidence properly admitted against him at trial.
Held: The Confrontation Clause is not violated by the admission of a nontestifying codefendant's confession with a proper limiting instruction when, as here, the confession is redacted to eliminate not only the defendant's name, but any reference to her existence. The Bruton Court recognized a very narrow exception to the almost invariable assumption of the law that jurors follow their instructions in the situation when the facially incriminating confession of a nontestifying codefendant is introduced at a joint trial and the jury is instructed to consider the confession only against the codefendant. In that situation, Bruton explained, the
risk that the jury will not follow its instructions is so great, and the consequences of that failure so vital to the defendant, that jurors will be assumed incapable of obeying their instructions. There are two important distinctions between this case and Bruton which cause it to fall outside the narrow exception Bruton created. First, in Bruton, the codefendant's confession expressly implicated the defendant as his accomplice, whereas here the confession was not incriminating on its face, but became so only when linked with evidence introduced later at trial. Where the necessity of such linkage is involved, there does not exist the overwhelming probability of jurors' inability to disregard incriminating inferences that is the foundation of Bruton. Second, evidence requiring linkage differs from evidence incriminating on its face in the practical effects which application of the Bruton exception would produce. If limited to facially incriminating confessions, Bruton can be complied with by redaction. If extended to confessions incriminating by connection, not only is that not possible, but it is not even possible to predict the admissibility of a confession in advance of trial. Compliance with the Court of Appeals' overbroad reading of Bruton could not be achieved without enormous costs to the criminal justice system. Pp. 481 U. S. 206-211.
781 F.2d 1201, reversed and remanded.
SCALIA, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and WHITE, BLACKMUN, POWELL, and O'CONNOR, JJ., joined. STEVENS, J., filed a dissenting opinion, in which BRENNAN and MARSHALL, JJ., joined, post, p. 481 U. S. 211.
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