Lee v. Illinois
476 U.S. 530 (1986)
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Rule of Law:
The confession of a non-testifying codefendant is presumptively unreliable and its use as substantive evidence against the accused violates the Confrontation Clause, unless the state rebuts that presumption by demonstrating sufficient independent indicia of reliability. The fact that the defendant's and codefendant's confessions 'interlock' on some points is not, in itself, sufficient to establish reliability if they diverge on significant facts bearing on the defendant's culpability.
Facts:
- Millie Lee and her boyfriend, Edwin Thomas, lived with Lee’s aunt, Mattie Darden.
- Lee and Thomas had previously discussed stopping Darden from harassing Lee, but Lee's confession stated Thomas never specified what he would do.
- On the evening of February 11, 1982, Darden's friend, Odessa Harris, intervened in an argument between Lee and Thomas.
- Following the intervention, Thomas stabbed Harris, and Lee subsequently stabbed Darden.
- Lee confessed to the police, portraying the events as spontaneous and stating she stabbed her aunt only after her aunt swung a knife at her, thus minimizing her own culpability and any premeditation.
- Thomas also confessed but stated that he and Lee had a pre-arranged plan to kill Darden.
- Thomas's confession claimed that just before the murders, he asked Lee if she wanted to 'go through with it,' and she affirmed, and that they had planned to deal with Harris as well.
- While the two confessions described the mechanics of the stabbings in similar ways, they were in direct conflict regarding premeditation and Lee's role in planning and initiating the murders.
Procedural Posture:
- Millie Lee and Edwin Thomas were charged with two counts of murder in an Illinois state trial court.
- The defendants agreed to a joint bench trial, withdrawing motions for separate trials.
- The trial court denied the defendants' motions to suppress their respective confessions.
- The trial judge found Lee guilty of both murders, expressly stating that he relied on portions of Thomas's confession as substantive evidence against her.
- Lee, the appellant, appealed her conviction to the Appellate Court of Illinois, arguing a violation of her Confrontation Clause rights.
- The intermediate appellate court affirmed the conviction, holding that the 'interlocking' nature of the confessions made them an exception to the Confrontation Clause issues raised in Bruton v. United States.
- The Illinois Supreme Court denied leave to appeal, after which the U.S. Supreme Court granted certiorari.
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Issue:
Does the use of a non-testifying codefendant's confession as substantive evidence against a defendant in a joint bench trial violate the defendant's Sixth Amendment Confrontation Clause rights when the codefendant's confession differs from the defendant's on crucial elements such as premeditation and the defendant's role in the crime?
Opinions:
Majority - Justice Brennan
Yes, the use of a non-testifying codefendant's confession as substantive evidence violated the defendant's Confrontation Clause rights. A codefendant’s confession that inculpates another defendant is presumptively unreliable due to the strong motivation to shift blame or curry favor. This presumption may be overcome by a showing of 'particularized guarantees of trustworthiness,' but that standard was not met here. The State's argument that the confessions were reliable because they 'interlocked' fails because, while they overlapped on some factual details, they diverged on the critical issues of premeditation and Lee's role in planning the crime. Thomas's statement portrayed Lee as a willing planner, whereas Lee's own statement suggested the events were spontaneous and less culpable on her part. Admitting a confession that is not thoroughly substantiated by the defendant's own confession on significant issues of culpability poses too great a threat to the accuracy of the verdict to be permitted under the Sixth Amendment.
Dissenting - Justice Blackmun
No, the use of the codefendant's confession did not violate the defendant's Confrontation Clause rights. Under the test from Ohio v. Roberts, the confession was admissible because the declarant (Thomas) was unavailable and the statement bore sufficient 'indicia of reliability.' Thomas was practically unavailable as he would have invoked his Fifth Amendment privilege against self-incrimination. The confession was reliable because it was unambiguously against Thomas's own penal interest; by claiming they planned the murders together, he implicated himself in a conspiracy and did not shift blame to Lee. The confession was also extensively corroborated by Lee's own statement in striking detail and by the physical evidence, rendering the discrepancies on premeditation insignificant in the overall context of their mutually reinforcing accounts.
Analysis:
This decision significantly strengthens the Confrontation Clause's protection against the use of accomplice testimony by affirming the strong presumption of unreliability for such confessions. The Court clarifies that the 'interlocking confessions' doctrine is not a blanket exception; reliability requires substantive agreement on the core issues of culpability and intent, not just on narrative details. By rejecting the confession here, the Court sets a high bar for admitting a non-testifying accomplice's statement, requiring courts to scrutinize discrepancies that go to the heart of the defendant's legal defense. This holding curtails the state's ability to use the confession of one defendant to bolster its case against another in a joint trial where the confessing defendant does not take the stand.
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