GRAY v. MARYLAND
523 U.S. 185 (1998)
JUDGES: BREYER, J., delivered the opinion of the Court, in which
STEVENS,
O'CONNOR, SOUTER, and GINSBURG, JJ., joined. SCALIA, J., filed a
dissenting
opinion, in which REHNQUIST, C. J., and KENNEDY and THOMAS, JJ.,
joined.
. . . .
III
Originally, the codefendant's confession in the case before us,
like that
in Bruton, referred to, and directly implicated another
defendant. The
State, however, redacted that confession by removing the
nonconfessing
defendant's name. Nonetheless, unlike Richardson's redacted
confession,
this confession refers directly to the "existence" of
the nonconfessing
defendant. The State has simply replaced the nonconfessing
defendant's
name with a kind of symbol, namely the word "deleted"
or a blank space set
off by commas. The redacted confession, for example, responded to
the
question "Who was in the group that beat Stacey," with
the phrase, "Me,
and a few other guys." And when the police witness read the
confession in court, he said the word "deleted" or
"deletion" where the
blank spaces appear. We therefore must decide a question that
Richardson
left open, namely whether redaction that replaces a defendant's
name with
an obvious indication of deletion, such as a blank space, the
word
"deleted," or a similar symbol, still falls within
Bruton's protective
rule. We hold that it does.
Bruton, as interpreted by Richardson, holds that certain
"powerfully
incriminating extrajudicial statements of a codefendant" --
those naming
another defendant -- considered as a class, are so prejudicial
that
limiting instructions cannot work. Unless the prosecutor wishes
to hold
separate trials or to use separate juries or to abandon use of
the
confession, he must redact the confession to reduce significantly
or to
eliminate the special prejudice that the Bruton Court found.
Redactions
that simply replace a name with an obvious blank space or a word
such as
"deleted" or a symbol or other similarly obvious
indications of alteration,
however, leave statements that, considered as a class, so closely
resemble
Bruton's unredacted statements that, in our view, the law must
require the
same result.
For one thing, a jury will often react similarly to an unredacted
confession and a confession redacted in this way, for the jury
will often
realize that the confession refers specifically to the defendant.
This is
true even when the State does not blatantly link the defendant to
the
deleted name, as it did in this case by asking whether Gray was
arrested on
the basis of information in Bell's confession as soon as the
officer had
finished reading the redacted statement. Consider a simplified
but typical
example, a confession that reads "I, Bob Smith, along with
Sam Jones,
robbed the bank." To replace the words "Sam Jones"
with an obvious blank
will not likely fool anyone. A juror somewhat familiar with
criminal law
would know immediately that the blank, in the phrase "I, Bob
Smith, along
with, robbed the bank," refers to defendant Jones. A juror
who does not
know the law and who therefore wonders to whom the blank might
refer need
only lift his eyes to Jones, sitting at counsel table, to find
what will
seem the obvious answer, at least if the juror hears the judge's
instruction not to consider the confession as evidence against
Jones, for
that instruction will provide an obvious reason for the blank. A
more
sophisticated juror, wondering if the blank refers to someone
else, might
also wonder how, if it did, the prosecutor could argue the
confession is
reliable, for the prosecutor, after all, has been arguing that
Jones, not
someone else, helped Smith commit the crime.
For another thing, the obvious deletion may well call the jurors'
attention
specially to the removed name. By encouraging the jury to
speculate about
the reference, the redaction may overemphasize the importance of
the
confession's accusation -- once the jurors work out the
reference. That is
why Judge Learned Hand, many years ago, wrote in a similar
instance that
blacking out the name of a codefendant not only "would have
been futile. .
. . There could not have been the slightest doubt as to whose
names had
been blacked out," but "even if there had been, that
blacking out itself
would have not only laid the doubt, but underscored the
answer."
Finally, Bruton's protected statements and statements redacted to
leave a
blank or some other similarly obvious alteration, function the
same way
grammatically. They are directly accusatory. Evans' statement in
Bruton
used a proper name to point explicitly to an accused defendant.
And Bruton
held that the "powerfully incriminating" effect of what
Justice Stewart
called "an out-of-court accusation," 391 U.S. at 138
(Stewart, J.,
concurring), creates a special, and vital, need for cross-
examination -- a
need that would be immediately obvious had the codefendant
pointed directly
to the defendant in the courtroom itself. The blank space in an
obviously
redacted confession also points directly to the defendant, and it
accuses
the defendant in a manner similar to Evans' use of Bruton's name
or to a
testifying codefendant's accusatory finger. By way of contrast,
the
factual statement at issue in Richardson -- a statement about
what others
said in the front seat of a car -- differs from directly
accusatory
evidence in this respect, for it does not point directly to a
defendant at
all.
We concede certain differences between Bruton and this case. A
confession
that uses a blank or the word "delete" (or, for that
matter, a first name
or a nickname) less obviously refers to the defendant than a
confession
that uses the defendant's full and proper name. Moreover, in some
instances the person to whom the blank refers may not be clear:
Although
the follow-up question asked by the State in this case eliminated
all
doubt, the reference might not be transparent in other cases in
which a
confession, like the present confession, uses two (or more)
blanks, even
though only one other defendant appears at trial, and in which
the trial
indicates that there are more participants than the confession
has named.
Nonetheless, as we have said, we believe that, considered as a
class,
redactions that replace a proper name with an obvious blank, the
word
"delete," a symbol, or similarly notify the jury that a
name has been
deleted are similar enough to Bruton's unredacted confessions as
to warrant
the same legal results.