Supreme Court of the United States
Samia v. United States
June 23, 2023599 U.S. 635
Summary
The Court held that admitting a nontestifying codefendant's testimonial confession did not violate the Confrontation Clause because the confession was modified to avoid directly identifying Samia and the trial court gave a proper limiting instruction. The Court distinguished directly accusatory confessions from statements that become incriminating only through later evidence or collateral inference, and concluded that the neutral reference to an "other person" was not an obvious redaction. The Court therefore affirmed the judgment below.
Holding
- Admission of a modified nontestifying codefendant confession at a joint trial. The Confrontation Clause does not bar admission of a nontestifying codefendant's confession when the confession does not directly inculpate the defendant and the jury is properly instructed to consider it only against the confessing codefendant.
- Whether neutral references created a directly accusatory confession through collateral inference. The neutral references to an "other person" did not make Stillwell's confession directly accusatory, even though other evidence may have enabled jurors to infer that the reference was to Samia.