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21 Maryland opinions name it 2 courts 1972–2022 1 in the last five years
The cases below were cited by Maryland courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
United States v. Jeffrey Allen Pendegraph and Clifford Eugene Mickelsgreen2 sentences1997We think the better approach is that typified by the holding in United States v. Pendegraph, supra, where the United States Court of Appeals for the District of Columbia Circuit held that “a redacted confession may still violate the Bruton rule if the statement compels a directly inculpating inference” between the redacted confession and the nonconfessing codefendant. 791 F.2d at 1465 (emphasis added) (where the word “individual” was substituted for Pendegraph’s name in his codefendant’s confession, the jury could infer that Pendegraph was that “individual” if only because there was no other p 1997We think the better approach is that typified by the holding in United States v. Pendegraph, supra, where the United States Court of Appeals for the District of Columbia Circuit held that “a redacted confession may still violate the Bruton rule if the statement compels a directly inculpating inference” between the redacted confession and the nonconfessing codefendant. 791 F.2d at 1465 (emphasis added) (where the word “individual” was substituted for Pendegraph’s name in his codefendant’s confession, the jury could infer that Pendegraph was that “individual” if only because there was no other p | 2 | 2 |
United States v. Stephen Washington, United States of America v. Christopher Jonesgreen2 sentences1997We think the better approach is that typified by the holding in United States v. Pendegraph, supra, where the United States Court of Appeals for the District of Columbia Circuit held that “a redacted confession may still violate the Bruton rule if the statement compels a directly inculpating inference” between the redacted confession and the nonconfessing codefendant. 791 F.2d at 1465 (emphasis added) (where the word “individual” was substituted for Pendegraph’s name in his codefendant’s confession, the jury could infer that Pendegraph was that “individual” if only because there was no other p 1997We think the better approach is that typified by the holding in United States v. Pendegraph, supra, where the United States Court of Appeals for the District of Columbia Circuit held that “a redacted confession may still violate the Bruton rule if the statement compels a directly inculpating inference” between the redacted confession and the nonconfessing codefendant. 791 F.2d at 1465 (emphasis added) (where the word “individual” was substituted for Pendegraph’s name in his codefendant’s confession, the jury could infer that Pendegraph was that “individual” if only because there was no other p | 2 | 2 |
Schneble v. Floridagreen2 sentences1974Schneble v. Florida, 405 U. S. 427 , 92 S. Ct. 1056 , 31 L.Ed.2d 340 (1972) (where “the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the co-defendant’s admission is so insignificant by comparison, that it is clear beyond a reasonable doubt that the improper use of the admission was harmless error”); Harrington v. California, 395 U. S. 250 , 89 S. Ct. 1726 , 23 L.Ed.2d 284 (1969) (where a Bruton error was found harmless because the testimony of other eyewitnesses made the questioned confession of a co-defendant relatively insignificant and cumulative). 1974Schneble v. Florida, 405 U. S. 427 , 92 S. Ct. 1056 , 31 L.Ed.2d 340 (1972) (where “the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the co-defendant’s admission is so insignificant by comparison, that it is clear beyond a reasonable doubt that the improper use of the admission was harmless error”); Harrington v. California, 395 U. S. 250 , 89 S. Ct. 1726 , 23 L.Ed.2d 284 (1969) (where a Bruton error was found harmless because the testimony of other eyewitnesses made the questioned confession of a co-defendant relatively insignificant and cumulative). | 1 | 3 |
Gray v. Marylandgreen2 sentences2022A redaction did not suffice in Gray v. Maryland, 523 U.S. 185, 192 (1998), where a non-testifying defendant’s confession that he and certain other named people had beaten the victim was replaced with the phrase “me, deleted, deleted, and a few other guys.” The Court held that such a redaction called attention to the fact that names had been removed that “obviously refer[red] to someone” and violated the Bruton rule. 523 U.S. at 195-96 . 2022A redaction did not suffice in Gray v. Maryland, 523 U.S. 185, 192 (1998), where a non-testifying defendant’s confession that he and certain other named people had beaten the victim was replaced with the phrase “me, deleted, deleted, and a few other guys.” The Court held that such a redaction called attention to the fact that names had been removed that “obviously refer[red] to someone” and violated the Bruton rule. 523 U.S. at 195-96 . | 1 | 2 |
Dorsey v. Stategreen2 sentences2017See Dorsey v. State, 276 Md. 638, 658-60 , 350 A.2d 665 (1976) (applying the harmless error analysis in the context of Bruton). 2017See Dorsey v. State, 276 Md. 638, 658-60 , 350 A.2d 665 (1976) (applying the harmless error analysis in the context of Bruton). | 1 | 2 |
United States v. Smallsgreen2 sentences2014See United States v. Avila Vargas, 570 F.3d 1004, 1008-09 (8th Cir.2009) (holding that Bruton does not apply to non-testimonial co-conspirator statements); United States v. Johnson, 581 F.3d 320, 326 (6th Cir.2009) (opining that “Because it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements”); United States v. Smalls, 605 F.3d 765 , 768 n. 2 (10th Cir.2010) (noting that “the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements”); United S 2014See United States v. Avila Vargas, 570 F.3d 1004, 1008-09 (8th Cir.2009) (holding that Bruton does not apply to non-testimonial co-conspirator statements); United States v. Johnson, 581 F.3d 320, 326 (6th Cir.2009) (opining that “Because it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements”); United States v. Smalls, 605 F.3d 765 , 768 n. 2 (10th Cir.2010) (noting that “the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements”); United S | 1 | 2 |
Nelson v. O'NEILgreen2 sentences1981For example, if McCallum had taken the witness stand at trial, Earhart would have no basis for invoking a Bruton claim now, because the confrontation clause as construed in Bruton "is violated only where the out-of-court hearsay statement is that of a declarant who is unavailable at trial 'for full and effective’ cross-examination.” Nelson v. O’Neil, 402 U.S. 622, 627 (1971) (emphasis in original). 1981For example, if McCallum had taken the witness stand at trial, Earhart would have no basis for invoking a Bruton claim now, because the confrontation clause as construed in Bruton "is violated only where the out-of-court hearsay statement is that of a declarant who is unavailable at trial 'for full and effective’ cross-examination.” Nelson v. O’Neil, 402 U.S. 622, 627 (1971) (emphasis in original). | 1 | 2 |
Brooks v. Stategreen2 sentences2017The State contends in the alternative that “Detective Wolfs and Andersons’s testimony about Butler’s statements did not mention Duncan even in the abstract,” and therefore, did not implicate Duncan, which is necessary for a Bruton violation to occur, citing: Gray v. Maryland, 523 U.S. 185, 195-96 , 118 S.Ct. 1151 , 140 L.Ed.2d 294 (1998); Richardson v. Marsh, 481 U.S. 200, 208 , 107 S.Ct. 1702 , 95 L.Ed.2d 176 (1987) (for a Bruton violation to occur, a statement by a codefendant must be “incriminating on its face” or expressly implicate a codefendant); United States v. Coleman, 349 F.3d 1077, 2017The State contends in the alternative that “Detective Wolfs and Andersons’s testimony about Butler’s statements did not mention Duncan even in the abstract,” and therefore, did not implicate Duncan, which is necessary for a Bruton violation to occur, citing: Gray v. Maryland, 523 U.S. 185, 195-96 , 118 S.Ct. 1151 , 140 L.Ed.2d 294 (1998); Richardson v. Marsh, 481 U.S. 200, 208 , 107 S.Ct. 1702 , 95 L.Ed.2d 176 (1987) (for a Bruton violation to occur, a statement by a codefendant must be “incriminating on its face” or expressly implicate a codefendant); United States v. Coleman, 349 F.3d 1077, | 1 | 1 |
United States v. Kenneth Coleman, United States of America v. Andre Worthy, United States of America v. Orlando Willisgreen2 sentences2017The State contends in the alternative that “Detective Wolfs and Andersons’s testimony about Butler’s statements did not mention Duncan even in the abstract,” and therefore, did not implicate Duncan, which is necessary for a Bruton violation to occur, citing: Gray v. Maryland, 523 U.S. 185, 195-96 , 118 S.Ct. 1151 , 140 L.Ed.2d 294 (1998); Richardson v. Marsh, 481 U.S. 200, 208 , 107 S.Ct. 1702 , 95 L.Ed.2d 176 (1987) (for a Bruton violation to occur, a statement by a codefendant must be “incriminating on its face” or expressly implicate a codefendant); United States v. Coleman, 349 F.3d 1077, 2017The State contends in the alternative that “Detective Wolfs and Andersons’s testimony about Butler’s statements did not mention Duncan even in the abstract,” and therefore, did not implicate Duncan, which is necessary for a Bruton violation to occur, citing: Gray v. Maryland, 523 U.S. 185, 195-96 , 118 S.Ct. 1151 , 140 L.Ed.2d 294 (1998); Richardson v. Marsh, 481 U.S. 200, 208 , 107 S.Ct. 1702 , 95 L.Ed.2d 176 (1987) (for a Bruton violation to occur, a statement by a codefendant must be “incriminating on its face” or expressly implicate a codefendant); United States v. Coleman, 349 F.3d 1077, | 1 | 1 |
United States v. Figueroa-Cartagenagreen2 sentences2014See United States v. Avila Vargas, 570 F.3d 1004, 1008-09 (8th Cir.2009) (holding that Bruton does not apply to non-testimonial co-conspirator statements); United States v. Johnson, 581 F.3d 320, 326 (6th Cir.2009) (opining that “Because it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements”); United States v. Smalls, 605 F.3d 765 , 768 n. 2 (10th Cir.2010) (noting that “the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements”); United S 2014See United States v. Avila Vargas, 570 F.3d 1004, 1008-09 (8th Cir.2009) (holding that Bruton does not apply to non-testimonial co-conspirator statements); United States v. Johnson, 581 F.3d 320, 326 (6th Cir.2009) (opining that “Because it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements”); United States v. Smalls, 605 F.3d 765 , 768 n. 2 (10th Cir.2010) (noting that “the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements”); United S | 1 | 1 |
Dionas v. Stategreen2 sentences2014See generally Dionas v. State, 436 Md. 97 (2013). 2014See generally Dionas v. State, 436 Md. 97 (2013). | 1 | 1 |
United States v. Avila Vargasgreen2 sentences2014See United States v. Avila Vargas, 570 F.3d 1004, 1008-09 (8th Cir.2009) (holding that Bruton does not apply to non-testimonial co-conspirator statements); United States v. Johnson, 581 F.3d 320, 326 (6th Cir.2009) (opining that “Because it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements”); United States v. Smalls, 605 F.3d 765 , 768 n. 2 (10th Cir.2010) (noting that “the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements”); United S 2014See United States v. Avila Vargas, 570 F.3d 1004, 1008-09 (8th Cir.2009) (holding that Bruton does not apply to non-testimonial co-conspirator statements); United States v. Johnson, 581 F.3d 320, 326 (6th Cir.2009) (opining that “Because it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements”); United States v. Smalls, 605 F.3d 765 , 768 n. 2 (10th Cir.2010) (noting that “the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements”); United S | 1 | 1 |
United States v. Johnsongreen2 sentences2014See United States v. Avila Vargas, 570 F.3d 1004, 1008-09 (8th Cir.2009) (holding that Bruton does not apply to non-testimonial co-conspirator statements); United States v. Johnson, 581 F.3d 320, 326 (6th Cir.2009) (opining that “Because it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements”); United States v. Smalls, 605 F.3d 765 , 768 n. 2 (10th Cir.2010) (noting that “the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements”); United S 2014See United States v. Avila Vargas, 570 F.3d 1004, 1008-09 (8th Cir.2009) (holding that Bruton does not apply to non-testimonial co-conspirator statements); United States v. Johnson, 581 F.3d 320, 326 (6th Cir.2009) (opining that “Because it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements”); United States v. Smalls, 605 F.3d 765 , 768 n. 2 (10th Cir.2010) (noting that “the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements”); United S | 1 | 1 |
Francis v. Franklingreen1 sentence2014Absent a clear Bruton violation, there exists an “almost invariable assumption of the law that jurors follow their instructions[.]” Richardson, 481 U.S. at 206 ; see also Francis v. Franklin, 471 U.S. 307 , 325 n.9 (1985). | 1 | 1 |
State v. Bowersgreen2 sentences2011In particular, Morris avers, as he did before the Court of Special Appeals, that “the trial court erred by authorizing the sham ‘joint trial’ in this case, and that the circumvention of Crawford was [but] one of the harms inflicted by this error.” (Emphasis added.) Presumably, the second harm inflicted by this “sham ‘joint trial’ ” is the “defrauding of] the jury....” Morris relies on State v. Bowers, 349 Md. 710, 724 , 709 A.2d 1255, 1262 (1998), for the precept that “[o]ur cases never intended to permit juries to be mislead.” (Citation omitted.) The State rejoins that Morris’s “current compl 2011In particular, Morris avers, as he did before the Court of Special Appeals, that “the trial court erred by authorizing the sham ‘joint trial’ in this case, and that the circumvention of Crawford was [but] one of the harms inflicted by this error.” (Emphasis added.) Presumably, the second harm inflicted by this “sham ‘joint trial’ ” is the “defrauding of] the jury....” Morris relies on State v. Bowers, 349 Md. 710, 724 , 709 A.2d 1255, 1262 (1998), for the precept that “[o]ur cases never intended to permit juries to be mislead.” (Citation omitted.) The State rejoins that Morris’s “current compl | 1 | 1 |
In Re Appeal No. 977green2 sentences1991See In re Appeal No. 977, 22 Md.App. 511, 516 , 323 A.2d 663 (1974). 1991See In re Appeal No. 977, 22 Md.App. 511, 516 , 323 A.2d 663 (1974). | 1 | 1 |
California v. Greenred2 sentences1981See California v. Green, 399 U.S. 149, 158-64 (1970). 1981See California v. Green, 399 U.S. 149, 158-64 (1970). | 1 | 1 |
| Parker v. Randolphred | 1 | 1 |
| Milton v. Wainwrightgreen | 1 | 1 |
| Younie v. Stategreen | 1 | 1 |
| Sutton v. Stategreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Richardson v. Marsh
green
2 sentences2022The Court suggested that redaction of the co-defendant’s name from the confession might have avoided a violation of the Confrontation Clause – a suggestion that it later confirmed in Richardson v. Marsh, 481 U.S. 200 (1987) (holding that redaction of confession to eliminate co-defendant’s name, together with limiting instruction that confession was to be considered only against the declarant-defendant, successfully avoided Bruton issue). 2017The State contends in the alternative that “Detective Wolfs and Andersons’s testimony about Butler’s statements did not mention Duncan even in the abstract,” and therefore, did not implicate Duncan, which is necessary for a Bruton violation to occur, citing: Gray v. Maryland, 523 U.S. 185, 195-96 , 118 S.Ct. 1151 , 140 L.Ed.2d 294 (1998); Richardson v. Marsh, 481 U.S. 200, 208 , 107 S.Ct. 1702 , 95 L.Ed.2d 176 (1987) (for a Bruton violation to occur, a statement by a codefendant must be “incriminating on its face” or expressly implicate a codefendant); United States v. Coleman, 349 F.3d 1077, | 5 | 1995–2022 |
Chapman v. California
red
2 sentences1981Those cases rejected the notion that a Bruton error can never be harmless under Chapman v. California, 386 U.S. 18 (1967). 1981Those cases rejected the notion that a Bruton error can never be harmless under Chapman v. California, 386 U.S. 18 (1967). | 3 | 1972–1981 |
Butz v. Glover Livestock Commission Co.
green
2 sentences1976Brown v. United States, 411 U. S. 223 , 93 S. Ct. 1565 , 36 L.Ed.2d 142 (1973) (concerned with a Bruton violation). 1976Brown v. United States, 411 U. S. 223 , 93 S. Ct. 1565 , 36 L.Ed.2d 142 (1973) (concerned with a Bruton violation). | 3 | 1974–1976 |
Brown v. United States
green
2 sentences1976Brown v. United States, 411 U. S. 223 , 93 S. Ct. 1565 , 36 L.Ed.2d 142 (1973) (concerned with a Bruton violation). 1976Brown v. United States, 411 U. S. 223 , 93 S. Ct. 1565 , 36 L.Ed.2d 142 (1973) (concerned with a Bruton violation). | 3 | 1974–1976 |
Harrington v. California
red
2 sentences1974Schneble v. Florida, 405 U. S. 427 , 92 S. Ct. 1056 , 31 L.Ed.2d 340 (1972) (where “the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the co-defendant’s admission is so insignificant by comparison, that it is clear beyond a reasonable doubt that the improper use of the admission was harmless error”); Harrington v. California, 395 U. S. 250 , 89 S. Ct. 1726 , 23 L.Ed.2d 284 (1969) (where a Bruton error was found harmless because the testimony of other eyewitnesses made the questioned confession of a co-defendant relatively insignificant and cumulative). 1974Schneble v. Florida, 405 U. S. 427 , 92 S. Ct. 1056 , 31 L.Ed.2d 340 (1972) (where “the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the co-defendant’s admission is so insignificant by comparison, that it is clear beyond a reasonable doubt that the improper use of the admission was harmless error”); Harrington v. California, 395 U. S. 250 , 89 S. Ct. 1726 , 23 L.Ed.2d 284 (1969) (where a Bruton error was found harmless because the testimony of other eyewitnesses made the questioned confession of a co-defendant relatively insignificant and cumulative). | 3 | 1972–1974 |
Bruton v. United States
green
2 sentences2017In support of this contention, the State argues that this case was “not one of those extraordinary circumstances where the jury cannot be trusted to follow instructions.” The State asserts in its brief: “With regard to the trial court’s instruction to disregard entirely a portion of Detective Wolfs testimony, this type of instruction is commonplace and there is no reason to doubt the jury’s ability to follow it.” But the Supreme Court said in Bruton that limiting instructions will generally be inadequate to cure the prejudicial impact of “powerfully incriminating extrajudicial statements of a 2017In support of this contention, the State argues that this case was “not one of those extraordinary circumstances where the jury cannot be trusted to follow instructions.” The State asserts in its brief: “With regard to the trial court’s instruction to disregard entirely a portion of Detective Wolfs testimony, this type of instruction is commonplace and there is no reason to doubt the jury’s ability to follow it.” But the Supreme Court said in Bruton that limiting instructions will generally be inadequate to cure the prejudicial impact of “powerfully incriminating extrajudicial statements of a | 2 | 1991–2017 |
State v. Payne & Bond
green
2 sentences2017State v. Payne, 440 Md. 680, 717 , 104 A.3d 142 (2014) (emphasis added) (alterations in original). 2 *546 Prior to trial in this case, the State conceded at the April 7 pre-trial hearing that Butler’s statements made during his proffer sessions and phone calls with Duncan “do constitute testimonial statements and therefore trigger the confrontation clause which therefore implicates Bruton.” At that hearing, the State also acknowledged that a mere redaction of Duncan’s name from any of Butler’s communications would not be sufficient to satisfy Bruton, but the State assured the circuit court tha 2017State v. Payne, 440 Md. 680, 717 , 104 A.3d 142 (2014) (emphasis added) (alterations in original). 2 *546 Prior to trial in this case, the State conceded at the April 7 pre-trial hearing that Butler’s statements made during his proffer sessions and phone calls with Duncan “do constitute testimonial statements and therefore trigger the confrontation clause which therefore implicates Bruton.” At that hearing, the State also acknowledged that a mere redaction of Duncan’s name from any of Butler’s communications would not be sufficient to satisfy Bruton, but the State assured the circuit court tha | 2 | 2015–2017 |
Crawford v. Washington
green
2 sentences2015But, for there to be what has become known as a “Bruton violation,” the statement at issue must qualify as “testimonial” hearsay, State v. Payne and Bond, 440 Md. 680, 716-18 , 104 A.3d 142 (2014), a standard confected by the Supreme Court in Crawford v. Washington, 541 U.S. 36, 68 , 124 S.Ct. 1354 , *473 158 L.Ed.2d 177 (2004). 2015But, for there to be what has become known as a “Bruton violation,” the statement at issue must qualify as “testimonial” hearsay, State v. Payne and Bond, 440 Md. 680, 716-18 , 104 A.3d 142 (2014), a standard confected by the Supreme Court in Crawford v. Washington, 541 U.S. 36, 68 , 124 S.Ct. 1354 , *473 158 L.Ed.2d 177 (2004). | 2 | 2014–2015 |
State v. Hutchinson
green
2 sentences1974App. 388 , n. 3: “In view of the basis of the Bruton , holding, and the role of a judge in a non-jury trial as discussed by the Court of Appeals in State v. Hutchinson, 260 Md. 277 , 271 A. 2d 641 , it would seem that there could be no Bruton error in a non-jury trial in Maryland.” Hutchinson, the predicate case, established simply that when a trial judge announces that he is factoring an admittedly inadmissible piece of evidence out of his decisional equation, we will indulge in the presumption that he, unlike a jury of laymen, is able to so *518 compartmentalize his thought process. 1972In view of the basis of the Bruton holding, and the role of a judge in a non-jury trial as discussed by the Court of Appeals in State v. Hutchinson, 260 Md. 227 , 271 A. 2d 641 , it would seem that there could be no Bruton error in a non-jury trial in Maryland. 4 . | 2 | 1972–1974 |
Wilson v. State
neutral
2 sentences1994Relying on the teachings of Lee v. Illinois and Cruz , the court believed, however, that the Bruton presumption was overcome because Lee’s confession and Wilson’s confession were “substantially identical in all significant aspects,” and that “[ijmportantly the circumstances of the actual taking of the independent confessions further demonstrate their strength and reliability.” 95 Md.App. at 693-694 , 622 A.2d 810 . 1994Relying on the teachings of Lee v. Illinois and Cruz , the court believed, however, that the Bruton presumption was overcome because Lee’s confession and Wilson’s confession were “substantially identical in all significant aspects,” and that “[ijmportantly the circumstances of the actual taking of the independent confessions further demonstrate their strength and reliability.” 95 Md.App. at 693-694 , 622 A.2d 810 . | 1 | 1994–1994 |
Great Atlantic & Pacific Tea Co. v. Supermarket Equipment Corp.
green
2 sentences1991Cf. Cruz v. New York, 481 U.S. 186, 193-94 , 107 S.Ct. 1714, 1719-20 , 95 L.Ed.2d 162 (1987) (holding that the Bruton rule applies even where the defendant’s own confession interlocks with a codefendant’s confession). 1991Cf. Cruz v. New York, 481 U.S. 186, 193-94 , 107 S.Ct. 1714, 1719-20 , 95 L.Ed.2d 162 (1987) (holding that the Bruton rule applies even where the defendant’s own confession interlocks with a codefendant’s confession). | 1 | 1991–1991 |
Cruz v. New York
green
2 sentences1991Cf. Cruz v. New York, 481 U.S. 186, 193-94 , 107 S.Ct. 1714, 1719-20 , 95 L.Ed.2d 162 (1987) (holding that the Bruton rule applies even where the defendant’s own confession interlocks with a codefendant’s confession). 1991Cf. Cruz v. New York, 481 U.S. 186, 193-94 , 107 S.Ct. 1714, 1719-20 , 95 L.Ed.2d 162 (1987) (holding that the Bruton rule applies even where the defendant’s own confession interlocks with a codefendant’s confession). | 1 | 1991–1991 |
Earhart v. State
green
2 sentences1981In response to this cacophony Judge Ridgely P. Melvin, Jr., speaking for this Court in Earhart v. State, 48 Md. 1981In response to this cacophony Judge Ridgely P. Melvin, Jr., speaking for this Court in Earhart v. State, 48 Md. | 1 | 1981–1981 |
| Pointer v. Texas green | 1 | 1972–1972 |
| Richardson v. State green | 1 | 1972–1972 |
| Ham v. State green | 1 | 1972–1972 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.