Samia v. United States

Supreme Court of the United States · 2023 · Evidence

599 U.S. 635 (2023)

Updated August 1, 2026

Evidenceredacted confessionsBruton limitsConfrontation Clausejoint trialsBrutonRichardsonGray

Facts

Samia, Hunter, and Stillwell were tried jointly on charges arising from the murder of Catherine Lee in the Philippines. Stillwell gave a formal, Mirandized postarrest confession admitting he was in the van when Lee was killed but claiming that Samia shot her. Because Stillwell did not testify, the Government introduced the confession through a DEA agent using neutral phrases like "the other person" instead of Samia's name. The district court instructed the jury both during the testimony and before deliberations that the confession was admissible only against Stillwell and could not be considered against Samia.

Issue

Does the Confrontation Clause bar admission at a joint trial of a nontestifying codefendant's testimonial confession when the confession is modified to avoid directly identifying the defendant and the jury receives a proper limiting instruction, even if other trial evidence might let jurors infer the defendant's identity?

Rule

The Confrontation Clause is not violated by admitting a nontestifying codefendant's testimonial confession at a joint trial when the confession does not directly inculpate the defendant, is not obviously redacted in a way that directly points to the defendant as in Gray, and is accompanied by a proper limiting instruction. Bruton remains a narrow exception for facially incriminating or directly accusatory confessions, while confessions that become incriminating only through linkage with other trial evidence fall outside that exception.

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

In a joint federal trial in Chicago, Nolan Pierce and Devin Cross are charged with conspiracy and armed robbery. Cross does not testify, but the government offers an agent's account of Cross's Mirandized confession: "I drove while the other person went inside and took the cash." The judge instructs the jury immediately and again before deliberations that the confession is admissible only against Cross.

Cross appeals, arguing that other trial evidence showed Pierce was the only alleged accomplice in the car. Under the governing rule, how should the court rule?

Explanation. The admission is proper under the majority's rule. The confession is testimonial, but ordinarily it is not treated as a witness 'against' Pierce if the jury is instructed to consider it only against Cross. Bruton is a narrow exception for facially incriminating confessions. A neutral reference like 'the other person' that becomes incriminating only by linkage to other evidence falls outside that exception when paired with a proper limiting instruction.