Gray v. Maryland

Supreme Court of the United States · 1998 · Evidence

523 U.S. 185 (1998)

Updated August 1, 2026

Evidenceredacted confessionsBrutonConfrontation Clausejoint trialcodefendant confessionredactionblank spaces

Facts

Bell confessed to police that he, Gray, and Vanlandingham participated in the beating that led to Stacey Williams' death. At Bell and Gray's joint trial, the judge denied Gray's severance motion and allowed Bell's confession after redacting Gray's and Vanlandingham's names, leaving blank spaces in the written version and having the detective say "deleted" or "deletion" when reading it aloud. Immediately afterward, the prosecutor asked whether, after receiving that information, the officer was able to arrest Gray, and the officer said yes. Bell did not testify, and the jury was instructed to consider the confession only against Bell, but Gray was convicted.

Issue

Does the Confrontation Clause, as interpreted in Bruton, bar admission at a joint trial of a nontestifying codefendant's confession when the defendant's name is replaced with an obvious blank space, the word "deleted," or a similar symbol, even if the jury is given a limiting instruction?

Rule

Bruton's protective rule applies to a nontestifying codefendant's confession that replaces the defendant's name with an obvious blank, the word "deleted," a symbol, or another similarly obvious indication of alteration. Such redactions remain within the class of facially accusatory, powerfully incriminating statements for which limiting instructions are inadequate, unlike a confession redacted to eliminate not only the defendant's name but any reference to the defendant's existence.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a joint armed-robbery trial in Cleveland, the prosecution offers a nontestifying codefendant's confession through a detective. The detective reads: "I went into the check-cashing store with [blank] and took the money," and the judge instructs the jury to consider the confession only against the confessor.

Is admission of the confession against the nonconfessing defendant most likely constitutional?

Explanation. The majority held that Bruton's protection applies when a nontestifying codefendant's confession substitutes an obvious blank for the defendant's name. Such a redaction still points directly to the defendant as a class of statements and remains powerfully incriminating, so a limiting instruction is inadequate.