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Name: Samia v. United States (2023) __ U.S. __ [143 S.Ct. 2004]
Case #: 22-196
Court: US Supreme Court
Opinion Date: 06/23/2023
Summary

Majority opinion: Justice Thomas delivered the opinion of the court, in which Chief Justice Roberts, and Justices Alito, Gorsuch, and Kavanaugh joined.
Concurring opinion: Justice Barrett joined the majority opinion in part and filed a separate opinion concurring in part and concurring in the judgment.
Dissenting opinions: Justice Kagan filed a dissenting opinion, in which Justices Sotomayor and Jackson joined. Justice Jackson also filed a dissenting opinion.

The confrontation clause does not bar the admission of a nontestifying codefendant’s confession where (1) the confession has been modified to avoid directly identifying the codefendant and (2) the court offers a limiting instruction. Samia and Stillwell were convicted of multiple federal offenses based on evidence they were paid to murder a person. At trial, the district court allowed the prosecution to introduce Stillwell’s confession, which implicated Samia in the murder. However, references to Samia were replaced with the “other person.” The district court also instructed the jury that Stillwell’s confession was admissible only as to Stillwell and should not be considered as to Samia. The U.S. Supreme Court ultimately granted certiorari to determine whether the admission of Stillwell’s altered confession violated Samia’s rights under the confrontation clause. Held: Affirmed. In Bruton v. United States (1968) 391 U. S. 123, the U.S. Supreme Court 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. After analyzing Bruton and other relevant precedent, a majority of the court concluded that the confrontation clause was not violated by the admission of Stillwell’s confession, which did not directly inculpate Samia and was subject to a proper limiting instruction. The law assumes that jurors can be relied upon to follow the trial judge’s instructions and the narrow exception to this rule that Bruton recognized applies only to “directly accusatory” incriminating statements. “[T]he neutral references to some ‘other person’ were not akin to an obvious blank or the word ‘deleted.’” Additionally, it would not have been feasible to further modify Stillwell’s confession to make it appear that Stillwell had acted alone. [Editor’s Note: In a footnote, the court noted that it has never opined as to whether rewriting a confession may serve as a proper method of redaction.]