Zafiro et al. v. United States
506 U.S. 534 (1993)
Rule of Law:
Federal Rule of Criminal Procedure 14 does not require severance of codefendants' trials as a matter of law when their defenses are mutually antagonistic. A district court should grant a severance only if there is a serious risk that a joint trial would compromise a specific trial right or prevent the jury from making a reliable judgment about guilt or innocence.
Facts:
- Gloria Zafiro, Jose Martinez, Salvador Garcia, and Alfonso Soto were allegedly involved in a drug distribution operation in the Chicago area.
- Government agents observed Garcia and Soto place a large box into a car and drive from Soto's bungalow to Zafiro's apartment.
- As Garcia and Soto carried the box into Zafiro's apartment building, agents identified themselves, causing the two men to drop the box and run into the apartment.
- Agents entered the apartment and found all four individuals—Zafiro, Martinez, Garcia, and Soto—in the living room.
- The dropped box contained 55 pounds of cocaine.
- A subsequent search of Zafiro's apartment revealed a suitcase in a closet containing 16 pounds of cocaine, heroin, and marijuana, with a sack of cash next to it.
- Soto testified he was innocent and did not know the contents of the box Garcia had asked for.
- Zafiro testified she was merely Martinez's girlfriend, knew nothing of the drug operation, and was unaware of the contents of the suitcase Martinez stored in her closet.
Procedural Posture:
- Gloria Zafiro, Jose Martinez, Salvador Garcia, and Alfonso Soto were indicted together in federal district court.
- During their joint trial, Garcia, Soto, Zafiro, and Martinez repeatedly moved for severance, arguing their defenses were mutually antagonistic.
- The District Court denied all motions for severance.
- A jury convicted all four petitioners of conspiracy and other drug-related offenses.
- Garcia, Soto, and Martinez (the petitioners) appealed to the U.S. Court of Appeals for the Seventh Circuit, which affirmed the District Court's denial of severance.
- The petitioners were granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does Federal Rule of Criminal Procedure 14 require severance as a matter of law when codefendants present mutually antagonistic defenses?
Opinions:
Majority - Justice O’Connor
No. Mutually antagonistic defenses are not prejudicial per se, and Rule 14 does not mandate severance even if prejudice is shown; it leaves the decision to the district court's discretion. There is a preference in the federal system for joint trials of defendants indicted together as they promote efficiency and serve justice by avoiding inconsistent verdicts. Severance is required only when there is a serious risk that a joint trial would compromise a specific trial right of one of the defendants or prevent the jury from making a reliable judgment about guilt or innocence. Here, the defendants did not articulate any specific prejudice, and any potential prejudice was cured by the district court's careful instructions to the jury, which admonished them to give separate consideration to each defendant and that closing arguments are not evidence. The jury is presumed to follow such instructions.
Concurring - Justice Stevens
No. The judgment should be affirmed because the defenses in this specific case did not rise to the level of being truly mutually antagonistic. Acceptance of one defendant's defense (e.g., Soto's ignorance) does not logically preclude the acquittal of another (e.g., Garcia). While agreeing with the outcome, the majority's stated 'preference' for joint trials is overly enthusiastic. Joint trials carry serious risks of prejudice, especially when one defendant effectively becomes a second prosecutor against another. The Court should not limit the traditional discretion of district courts to grant severance in cases where defenses are genuinely irreconcilable, as joinder can improperly shift the prosecutor's burden of proof.
Analysis:
This decision solidifies the high bar for defendants seeking to sever their trials from those of their codefendants. It explicitly rejects a bright-line rule that mutually antagonistic defenses automatically require severance, instead vesting significant discretion in trial judges. The ruling forces defendants to demonstrate a specific, serious risk of actual prejudice, such as the violation of a concrete trial right, rather than merely pointing to conflicting defense theories. Consequently, this precedent strengthens the federal system's preference for joint trials on the grounds of judicial efficiency, making it more difficult for defendants to obtain separate trials.
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