Tennessee v. Street
105 S. Ct. 2078, 85 L. Ed. 2d 425, 1985 U.S. LEXIS 9 (1985)
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Rule of Law:
The Confrontation Clause of the Sixth Amendment is not violated by the introduction of a non-testifying accomplice's confession for the limited, non-hearsay purpose of rebutting a defendant's claim that their own confession was coercively derived from the accomplice's statement.
Facts:
- On August 27, 1981, Ben Tester was found dead, hanging from a tree in his yard, and his house had been ransacked.
- Tester's neighbor, respondent Street, was arrested for the murder.
- During a police interview on September 17, 1981, Street gave a detailed confession, implicating himself and an accomplice, Clifford Peele, in the burglary and murder of Tester.
- At his trial, Street testified that his confession was not voluntary.
- Street claimed his confession was coerced because Sheriff Papantoniou read from Peele's written statement and directed Street to say the same thing.
Procedural Posture:
- Street was prosecuted by the State of Tennessee in a state trial court for the murder of Ben Tester.
- At trial, the prosecution introduced Street's confession; Street testified it was coerced by the Sheriff reading from an accomplice's (Peele's) statement.
- To rebut this claim, the trial court allowed the prosecution to introduce Peele's confession for the limited purpose of comparison, accompanied by a limiting instruction.
- The jury convicted Street, and he was sentenced to life in prison.
- Street, as appellant, appealed to the Court of Criminal Appeals of Tennessee, which reversed the conviction, holding the introduction of Peele's confession violated the Confrontation Clause.
- The State of Tennessee, as appellee, had its application for permission to appeal denied by the Supreme Court of Tennessee.
- The United States Supreme Court granted the State of Tennessee's petition for a writ of certiorari.
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Issue:
Does the introduction of a non-testifying accomplice's confession for the non-hearsay purpose of rebutting the defendant's claim that his own confession was coerced violate the defendant's Sixth Amendment Confrontation Clause rights?
Opinions:
Majority - Chief Justice Burger
No, the introduction of a non-testifying accomplice's confession for this limited non-hearsay purpose does not violate the defendant's Sixth Amendment Confrontation Clause rights. The court reasoned that Peele's confession was not offered to prove the truth of the matters asserted within it (that Street committed the murder), but for the legitimate non-hearsay purpose of allowing the jury to compare it with Street's confession and evaluate the credibility of Street's coercion claim. The Confrontation Clause's primary concern is with hearsay evidence, which was not at issue here. The actual witness against Street on this matter was Sheriff Papantoniou, who introduced the statement and was available for full cross-examination. The court held that the trial judge's limiting instruction, which told the jury not to consider the truthfulness of Peele's statement, was sufficient to protect the defendant's rights, distinguishing this case from Bruton v. United States where the confession was powerfully incriminating hearsay.
Concurring - Justice Brennan
No, the confession was admissible for the non-hearsay purpose of rebuttal. This concurrence emphasizes that the trial court's limiting instruction, by itself, is not always sufficient to justify admission, per Bruton v. United States. However, in this specific case, admission was permissible because the defendant, Street, created the necessity for its introduction by claiming his confession was a coerced imitation of Peele's statement. The confession was essential for the State's rebuttal, no alternative would have sufficed, and there was no indication that the State was improperly trying to place prejudicial hearsay before the jury.
Analysis:
This case establishes a significant 'non-hearsay purpose' exception to the general prohibition against admitting a non-testifying accomplice's confession against a defendant. It clarifies that the Confrontation Clause is not an absolute bar to such evidence; rather, its application hinges on the purpose for which the evidence is introduced. By endorsing the use of limiting instructions in this context, the decision reinforces the presumption that juries can follow judicial instructions to consider evidence for one purpose while disregarding it for another. This ruling provides prosecutors with a critical tool to rebut specific defense claims, particularly those that 'open the door' by putting the circumstances of a confession at issue.
