Cruz v. New York
481 U.S. 186 (1987)
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Rule of Law:
Under the Sixth Amendment's Confrontation Clause, a nontestifying codefendant's confession that incriminates another defendant is inadmissible at their joint trial. This rule applies even if the defendant's own confession, which "interlocks" with the codefendant's, is also admitted into evidence.
Facts:
- Eulogio Cruz and his brother Benjamin Cruz were longtime friends with Norberto Cruz and his brother Jerry Cruz, but the two sets of brothers were not related.
- During an investigation into Jerry Cruz's murder, Norberto told police about a prior conversation he had with Eulogio and Benjamin.
- Norberto claimed that Eulogio confided that he and Benjamin had robbed a Bronx gas station, during which a struggle ensued, the attendant shot Eulogio in the arm, and Benjamin then killed the attendant.
- Later, while being questioned by police about Jerry's murder, Benjamin spontaneously confessed to the gas station murder.
- Benjamin subsequently gave a detailed videotaped confession, admitting that he, Eulogio, and two others had robbed the gas station and that he had killed the attendant after the attendant shot Eulogio.
Procedural Posture:
- Eulogio Cruz and his brother Benjamin were indicted for felony murder of a gas station attendant.
- Eulogio and Benjamin were tried jointly in a New York state trial court, over Eulogio's objection.
- At trial, the judge admitted Benjamin's videotaped confession into evidence but instructed the jury not to use it against Eulogio.
- The jury convicted both defendants.
- Eulogio Cruz (appellant) appealed to the New York Court of Appeals (the state's highest court), which affirmed his conviction, holding that the Bruton rule does not apply to cases involving interlocking confessions.
- The United States Supreme Court granted certiorari to review the judgment of the New York Court of Appeals.
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Issue:
Does the Confrontation Clause bar the admission of a nontestifying codefendant's confession that incriminates the defendant at their joint trial, even if the defendant’s own interlocking confession is also admitted into evidence?
Opinions:
Majority - Justice Scalia
Yes, the Confrontation Clause bars the admission of a nontestifying codefendant's confession incriminating the defendant at their joint trial, even if the jury is instructed not to consider it against the defendant and even if the defendant's own confession is admitted against him. The Court rejects the exception for "interlocking" confessions proposed in Parker v. Randolph. The reasoning in Bruton v. United States, which found that juries cannot be expected to follow limiting instructions regarding a codefendant's powerfully incriminating confession, applies with equal force here. In fact, a codefendant's confession that corroborates the defendant's alleged confession is even more damaging, as it undermines the defendant's ability to argue that his own confession was inaccurately reported, coerced, or false. The reliability of an interlocking confession is not relevant to whether the jury will improperly use it against the defendant; it is relevant only to whether it might be directly admissible under a hearsay exception, which is a separate inquiry.
Dissenting - Justice White
No, the Confrontation Clause should not bar the admission of a nontestifying codefendant's confession when it interlocks with the defendant's own properly admitted confession. The rule in Bruton was designed to protect a defendant from the "devastating" effect of a codefendant's confession where the defendant has not confessed himself. When a defendant has already confessed, his own confession is the most probative and damaging evidence against him, and the devastating effect Bruton sought to prevent is already present. The codefendant's interlocking confession is merely cumulative and does not pose the same substantial threat to the defendant's rights. Extending the Bruton prophylactic rule to this context is an exercise in "remorseless logic" that ignores common sense and imposes significant burdens on the justice system by discouraging joint trials.
Analysis:
This decision resolves the uncertainty left by the divided Court in Parker v. Randolph by definitively rejecting the "interlocking confessions" exception to the Bruton rule. The Court's holding reinforces the principle that a defendant's Sixth Amendment right to confront witnesses is paramount and cannot be overcome by a judicial instruction in the context of a nontestifying codefendant's confession. By creating a bright-line rule, the decision forces prosecutors to choose between severing trials, forgoing the use of the confession, or redacting the confession to eliminate all references to the non-confessing defendant. This strengthens protections for defendants in joint trials but also complicates prosecutorial strategy.
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