Samia v. U.S. (2023)

Supplements Casebook at the top of page 465

Case Summary: Samia v. United States

The Supreme Court further explored Bruton redactions in Samia v. United States (2023). The case arose from the federal prosecution of “a transnational criminal organization,” responsible for numerous crimes. Among those crimes, the prosecution alleged, the organization hired Carl Stillwell and Adam Samia to murder Catherine Lee, a real estate broker in the Philippines. After Lee’s murder, Stillwell admitted to a Drug Enforcement Administration agent that he was driving a van with Samia in it when Samia shot Lee.

The prosecution tried Stillwell and Samia in a single trial. The judge required that Stillwell’s out-of-court confession – admissible only against Stillwell – be modified to exclude any explicit references to Samia. Consequently, the DEA agent testified that Stillwell confessed to being present for the murder with an “other person,” and that “the other person he was with” pulled the trigger. The judge then instructed the jurors that Stillwell’s confession was “only admissible as to Mr. Stillwell and not as to Mr. Samia.” (Stillwell did not testify.)

Samia challenged his resulting conviction under the Bruton line of cases, contending that the redaction was insufficient because, in light of the other evidence in the case, the jury would have had little doubt that the “other person” was Samia – rendering the redaction, in effect, no different than the blank space in Gray v. Maryland.

Writing for the Court, Justice Thomas disagreed with Samia, concluding that the redaction substituting “other person” for “Samia” was sufficient, and distinguishing Bruton and Gray as follows:

“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.’”

The majority opinion then concluded as follows:

“The Confrontation Clause ensures that defendants have the opportunity to confront witnesses against them, but it does not provide a freestanding guarantee against the risk of potential prejudice that may arise inferentially in a joint trial. Here, the 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.”

Click link below for an edited opinion.