![]() In that case, the prosecution had redacted the confession by substituting a blank (or the word “deleted”) for the defendant’s name. 185 (1998), the Court held that a redacted confession violated the Bruton rule where the fact of redaction was obvious to the jury. ![]() 200 (1987), the Court held that where the co-defendant’s confession was redacted to “eliminate not only the defendant’s name, but any reference to his or her existence,” it fell outside the scope of the Bruton. ” The conflict among the circuits arises over their reading of two post- Bruton cases. Samia argues that the Second Circuit’s “decision implicates a circuit conflict on the question whether a codefendant’s redacted out-of-court confession must be assessed in isolation or in its broader context when determining whether a violation of the Confrontation Clause has occurred.” If Stillwell’s confession were assessed in its broader context, Samia argues, it would be “immediately obvious that the confession could refer only to. The court stated that, in considering whether a redaction is sufficient, the court asks “whether the neutral allusion sufficiently conceals the fact of explicit identification to eliminate the overwhelming probability that a jury hearing the confession at a joint trial will not be able to follow an appropriate limiting instruction.” The court rejected Samia’s argument that, given the context, “jurors would immediately infer that Stillwell’s references to ‘another person’ referred to himself.” Rather, the court cited Second Circuit precedent requiring it to consider the redacted statement “separate and apart from any other evidence admitted at trial.” Applying that standard, the court of appeals concluded that the redactions avoided any prejudicial error because the DEA agent used “neutral terms” that did not “explicit identif” Samia. And in particular, the Second Circuit held that the admission of a version of Stillwell’s statement through the DEA agent’s testimony did not violate Samia’s Confrontation Clause right under Bruton. On appeal, the Second Circuit vacated the defendants’ convictions on certain counts, but rejected the defendants’ other claims and upheld the remaining convictions, for conspiring to kidnap and murder in a foreign country and conspiring to launder money. Stillwell w driving.” The jury returned guilty verdicts on all counts against all three defendants, and the court sentenced Samia to a life term of imprisonment. The agent recounted Stillwell’s statements, for example, that “he had met somebody else” in the Philippines that “the person that he was with” had carried a firearm and that “the other person he was with pulled the trigger on that woman,” Catherine Lee, “in a van that he and Mr. At trial, a DEA agent testified regarding the contents of Stillwell’s statement in a manner consistent with its approved form, avoiding any reference to Samia’s identity. As redacted, Stillwell’s confession did not name Samia and read as though there were no redactions. But the government proposed redactions, and the district court added more redactions. 123 (1968), which held that the admission of a non-testifying codefendant’s confession expressly implicating the defendant violates the Confrontation Clause even if the jury is instructed not to consider the confession as to the defendant. The unredacted version directly implicated Samia, and so could not be introduced in that form under Bruton v. At their joint trial in the Southern District of New York, the government introduced a redacted version of Stillwell’s confession. Samia and one Carl Stillwell were arrested and charged with being those two men. ![]() Lee was murdered by two individuals hired by LeRoux’s underling Billy Hunter. At issue is “hether admitting a codefendant’s redacted out-of-court confession that immediately inculpates a defendant based on the surrounding context violates the defendant’s rights under the Confrontation Clause of the Sixth Amendment.” Petitioner Adam Samia worked as a hitman for Paul LeRoux, the head of “a transnational criminal organization” through which “he committed ‘an array of crimes worthy of a James Bond villain.’” In January 2012, LeRoux ordered the murder of Catherine Lee, a real estate broker in the Philippines whom LeRoux believed had stolen money from him. This Report summarizes cases granted review on Decem(Part I).
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