Samia v. United States

by Supreme Court of the 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.

At trial, the Government’s theory of the case was that Hunter had hired Samia and Stillwell to pose as real-estate buyers and visit properties with Lee and that Samia, Stillwell, and Lee were in a van driven by Stillwell when Samia shot Lee. As part of the Government’s case in chief, a DEA agent testified that Stillwell had confessed to “a time when the other person he was with pulled the trigger on that woman in a van that he and Mr. Stillwell was driving.” (Emphasis added.) Other portions of the agent’s testimony recounting Stillwell’s confession used the “other person” descriptor to refer to someone with whom Stillwell had traveled and lived and who carried a particular firearm. Both before the agent’s testimony and again prior to deliberations, the District Court instructed the jury that the agent’s testimony about Stillwell’s confession was admissible only as to Stillwell and should not be considered as to Samia or Hunter. Samia and his codefendants were convicted on all counts. On appeal, Samia argued that the admission of Stillwell’s confession was constitutional error because other evidence and statements at trial enabled the jury to immediately infer that the “other person” described in the confession was Samia himself. The Second Circuit, pointing to the established practice of replacing a defendant’s name with a neutral noun or pronoun in a nontestifying codefendant’s confession, held that the admission of Stillwell’s confession did not violate Samia’s Confrontation Clause rights.

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.

(2) This historical practice is in accord with the law’s broader assumption that jurors will “ ‘attend closely the particular language of [limiting] instructions in a criminal case and strive to understand, make sense of, and follow’ ” them. United States v. Olano, 507 U. S. 725, 740. And the presumption that jurors follow limiting instructions applies to statements that are substantially more credible and inculpatory than a codefendant’s confession. See, e.g., Harris v. New York, 401 U. S. 222, 223–225. To disregard or to make unnecessary exceptions to this principle “would make inroads into th[e] entire complex code of … criminal evidentiary law, and would threaten other large areas of trial jurisprudence.” Spencer v. Texas, 385 U. S. 554, 562. Pp. 8–9.

(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.

Thomas, J., delivered the opinion of the Court, in which Roberts, C. J., and Alito, Gorsuch, and Kavanaugh, JJ., joined, and in which Barrett, J., joined as to all but Part II–A. Barrett, J., filed an opinion concurring in part and concurring in the judgment. Kagan, J., filed a dissenting opinion, in which Sotomayor and Jackson, JJ., joined. Jackson, J., filed a dissenting opinion.

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