A defendant’s confrontation rights were not violated by the introduction of his non-testifying codefendant’s statement to the police, because the statement did not mention the defendant. In affirming the district courts denial of a state prisoner’s habeas petition, the court noted that the substance of the co-defendants statement to the police was never admitted into evidence. Further, the logical inference of the statement, i.e., that the codefendant’s statement had implicated the defendant, was properly admitted through the testimony of another witness. Finally, the court held that the codefendant did not “bear testimony” against the defendant under Crawford v. Washington (2004) 541 U.S. 36, because the co-defendants statement to the police was never admitted into evidence.
Case Summaries