# Samia v. United States

Note: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
SAMIA, AKA SAMIC v. UNITED STATES CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT No. 22–196. Argued March 29, 2023—Decided June 23, 2023
Petitioner Adam Samia, along with Joseph Hunter and Carl Stillwell, were arrested by the U. S. Drug Enforcement Administration and charged with a variety of offenses related to the murder-for-hire of Catherine Lee, a real-estate broker. The Government tried all three defendants jointly in the Southern District of New York. Prior to trial, the Government moved to admit Stillwell’s postarrest confession in which he admitted that he had been in the van in which Lee was killed, but he claimed that Samia had shot Lee. Since Stillwell would not be testifying on his own behalf and the full confession implicated Samia, the Government proposed that the confession be introduced through the testimony of a DEA agent, who would testify to the content of Stillwell’s confession in a way that eliminated Samia’s name while avoiding any obvious indications of redaction. The District Court granted the Government’s motion with additional alterations to conform to its understanding of this Court’s Confrontation Clause precedents.
Held: The Confrontation Clause was not violated by the admission of a nontestifying codefendant’s confession that did not directly inculpate the defendant and was subject to a proper limiting instruction. Pp. 5–17.
(a) Stillwell’s formal, Mirandized confession to authorities is testimonial and thus falls within the ambit of the Sixth Amendment’s Confrontation Clause, which forbids the introduction of out-of-court “testimonial” statements unless the witness is unavailable and the defendant has had the chance to cross-examine the witness previously. See Crawford v. Washington, 541 U. S. 36, 52–54. The Clause, however, applies only to witnesses “against the accused.” Id., at 50. And “[o]rdinarily, a witness whose testimony is introduced at a joint trial is not considered to be a witness ‘against’ a defendant if the jury is instructed to consider that testimony only against a codefendant.” Richardson v. Marsh, 481 U. S. 200, 206. This general rule is consistent with the Clause’s text, historical practice, and the law’s reliance on limiting instructions in other contexts. Pp. 5–9.
(1) Longstanding practice permitted a nontestifying codefendant’s confession to be admitted in a joint trial so long as the jury was properly instructed not to consider it against the nonconfessing defendant. This practice is identified in early treatises, see, e.g., S. Phillipps, Law of Evidence 82; in the early cases of this Court, see, e.g., Sparf v. United States, 156 U. S. 51, 58; United States v. Ball, 163 U. S. 662, 672; and in many States with a similar constitutional right of confrontation, see, e.g., State v. Workman, 15 S. C. 540, 545. Notably, none of these treatises or cases suggests that a confession naming a codefendant must in all cases be altered to refer to “another person” (or something similar). Thus, while it is unclear that any alteration to Stillwell’s confession was necessary, historical practice suggests that altering a nontestifying codefendant’s confession not to name the defendant, coupled with a limiting instruction, was enough to permit the introduction of such confessions at least as an evidentiary matter. Pp. 6–8.
(b) The Court in Bruton v. United States, 391 U. S. 123, “recognized a narrow exception to” the presumption that juries follow their instructions, holding “that a defendant is deprived of his Sixth Amendment right of confrontation when the facially incriminating confession of a nontestifying codefendant is introduced at their joint trial,” even with a proper instruction. Richardson, 481 U. S., at 207. In Bruton, the prosecution introduced a confession by Bruton’s codefendant that implicated Bruton by name. The Court held that the confession’s introduction substantially threatened Bruton’s right to confront the witnesses against him, reasoning that “there are some contexts in which the risk that the jury will not, or cannot, follow instructions is so great, and the consequences of failure so vital to the defendant, that the practical and human limitations of the jury system cannot be ignored.” 391 U. S., at 135.
In Richardson v. Marsh, the Court “decline[d] to extend [Bruton] further” to “confessions that do not name the defendant.” 481 U. S., at 211. Richardson involved a redacted confession that “was not incriminating on its face, and became so only when linked with evidence introduced later at trial.” Id., at 208. In such cases of inferential incrimination, the Court posited that “the judge’s instruction may well be successful in dissuading the jury from entering onto the path of inference.” Ibid.
The Court in Gray v. Maryland, 523 U. S. 185, 194, later qualified Richardson by holding that certain obviously redacted confessions might be “directly accusatory,” and thus fall within Bruton’s rule, even if they did not specifically use a defendant’s name. Gray involved whether admission of a co-defendant’s confession altered “by substituting for the defendant’s name in the confession a blank space or the word ‘deleted’ ” violated the Confrontation Clause. Id., at 188. The Court in Gray concluded that, when a redacted confession “simply replace[s] a name with an obvious blank space or a word such as ‘deleted’ or a symbol or other similarly obvious indications of alteration,” the evidence “so closely resemble[s] Bruton’s unredacted statements that … the law must require the same result.” Id., at 192. Pp. 9–14.
(c) The Court’s precedents in this area distinguish between confessions that directly implicate a defendant and those that do so indirectly. Accordingly, neither Bruton, Richardson, nor Gray provides license to flyspeck trial transcripts in search of evidence that could give rise to a collateral inference that a defendant was named in an altered confession. Here, the District Court’s admission of Stillwell’s confession, accompanied by a limiting instruction, did not run afoul of this Court’s precedents. Stillwell’s confession was redacted to avoid naming Samia, satisfying Bruton’s rule. And, it was not obviously redacted in a manner resembling the confession in Gray; the neutral references to some “other person” were not akin to an obvious blank or the word “deleted.” Pp. 14–16.
(d) Expanding Bruton in the way Samia proposes would be inconsistent with longstanding practice and this Court’s precedents, would work an unnecessary and imprudent change in law, and would require federal and state trial courts to conduct extensive pretrial hearings. Because it would be impractical to fully police juror inferences, the likely practical consequence of extending Bruton here would be to mandate severance whenever the prosecution wishes to introduce the confession of a nontestifying codefendant in a joint trial. But, as the Court has observed, that is “too high” a price to pay. Richardson, 481 U. S., at 210. Samia’s proposal is not compelled by the Confrontation Clause, and it ignores both the “vital role” joint trials play in the criminal justice system, and the fact that confessions are “ ‘essential to society’s compelling interest in finding, convicting, and punishing those who violate the law.’ ” Id., at 209–210. Pp. 16–17.
Affirmed.
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