21 Washington opinions name it 2 courts 1976–2026 1 in the last five years
The cases below were cited by Washington 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. Winstongreen2 sentences2016See, e.g., United States v. Winston, 55 F. App'x 289 , 294 4 It should be noted that in Gray, the phrase "a few other guys" was contained in the original statement and was not a replacement for more specific language. 7 No. 91438-9 (6th Cir. 2003) ("several of our sister circuits have noted that a Bruton violation can be avoided by replacing the co-defendant's name with a neutral pronoun or other generalized phrase"). 2016See, e.g., United States v. Winston, 55 F. App'x 289 , 294 4 It should be noted that in Gray, the phrase "a few other guys" was contained in the original statement and was not a replacement for more specific language. 7 No. 91438-9 (6th Cir. 2003) ("several of our sister circuits have noted that a Bruton violation can be avoided by replacing the co-defendant's name with a neutral pronoun or other generalized phrase"). | 4 | 4 |
United States v. Johnsongreen2 sentences2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l 2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l | 3 | 3 |
United States v. Inez Eaton Guerrero, Patrick John O'shea, Stephen Michael Kessler, Cynthia Walker and Donald Gene Boothgreen2 sentences2011But these cases held such uses to be harmless error, where violation of the Bruton rule did not result in prejudice "`so devastating that the jury could not be expected to disregard it if the district court had instructed them to do so.'" Larry, 108 Wash.App. at 904 n. 2, 34 P.3d 241 (quoting United States v. Guerrero, 756 F.2d 1342, 1348 (9th Cir. 1984)). [14] Jackson did not use Smith's last name during his opening statement. 2011But these cases held such uses to be harmless error, where violation of the Bruton rule did not result in prejudice "`so devastating that the jury could not be expected to disregard it if the district court had instructed them to do so.'" Larry, 108 Wash.App. at 904 n. 2, 34 P.3d 241 (quoting United States v. Guerrero, 756 F.2d 1342, 1348 (9th Cir. 1984)). [14] Jackson did not use Smith's last name during his opening statement. | 3 | 3 |
Bruton v. United Statesgreen2 sentences2026Accordingly, “while it may not always be simple for the members of a jury to obey the instruction that they disregard an incriminating inference, there does not exist the overwhelming probability of their inability to do so that is the foundation of Bruton’s exception to the general rule.” Id. 2016Id. at 127-28 . ¶15 Following Bruton , the Supreme Court explored the Bruton doctrine by fleshing out how a Bruton violation should be handled and what curative measures could be implemented to avoid the effect a codefendant’s confession could have on the nonconfessing defendant’s defense. | 2 | 6 |
Gray v. Marylandgreen2 sentences2016If they do not, then no Bruton violation has occurred. ¶11 Marsh and Gray v. Maryland, 523 U.S. 185 , 118 S. Ct. 1151 , 140 L. 2016If they do not, then no Bruton violation has occurred. ¶11 Marsh and Gray v. Maryland, 523 U.S. 185 , 118 S. Ct. 1151 , 140 L. | 2 | 5 |
Harrington v. Californiared2 sentences2016A sampling of the remaining evidence included (1) DNA evidence linking the defendant to the murder, (2) evidence that a bloodhound led investigators directly to the defendant, (3) numerous inconsistencies in the testimony of the defendant, detracting from his credibility, and (4) “evidence suggesting that [the victim] had died before she could dress or put on her customary makeup; evidence suggesting that [she] had been dressed and her bags packed by ‘somebody who doesn’t know anything about women.’ ” Id. ¶71 In addition to this court’s harmless error jurisprudence, a look back at Harrington, 2016A sampling of the remaining evidence included (1) DNA evidence linking the defendant to the murder, (2) evidence that a bloodhound led investigators directly to the defendant, (3) numerous inconsistencies in the testimony of the defendant, detracting from his credibility, and (4) “evidence suggesting that [the victim] had died before she could dress or put on her customary makeup; evidence suggesting that [she] had been dressed and her bags packed by ‘somebody who doesn’t know anything about women.’ ” Id. ¶71 In addition to this court’s harmless error jurisprudence, a look back at Harrington, | 2 | 3 |
United States v. Berriosgreen2 sentences2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l 2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l | 2 | 2 |
United States v. Clarkgreen2 sentences2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l 2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l | 2 | 2 |
United States v. Vejar-Uriasgreen2 sentences2016But see United States v. Gonzalez, 183 F .3d 1315, 1322 (11th Cir. 1999) (holding that a redacted confession implicating a precise number of the confessor's codefendants violated the confrontation clause); United States v. Vejar-Urias, 165 F.3d 337, 340 (5th Cir. 1999) (holding that use of'"someone"' violated the confrontation clause). 2016But see United States v. Gonzalez, 183 F .3d 1315, 1322 (11th Cir. 1999) (holding that a redacted confession implicating a precise number of the confessor's codefendants violated the confrontation clause); United States v. Vejar-Urias, 165 F.3d 337, 340 (5th Cir. 1999) (holding that use of'"someone"' violated the confrontation clause). | 2 | 2 |
United States v. Spotted Elkgreen2 sentences2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l 2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l | 2 | 2 |
United States v. Reginald Dargan, Jr.green2 sentences2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l 2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l | 2 | 2 |
Thomas v. United Statesgreen2 sentences2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l 2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l | 2 | 2 |
Richardson v. Marshgreen2 sentences2016The court reiterated the harm against which Bruton protects when it stated that “while it may not always be simple for members of the jury to obey the instruction that they disregard an incriminating inference, there does not exist the overwhelming probability of their inability to do so that is the foundation of Bruton’s exception to the general rule.” Id. at 208 . ¶48 In the same year, the Court decided Cruz , overruling Parker v. Randolph, 442 U.S. 62 , 99 S. Ct. 2132 , 60 L. 2016The court reiterated the harm against which Bruton 5 The evidence technically was not admitted against Lee, but because the judge relied so heavily on it in convicting her, the Court treated it as a de facto admission of evidence. 7 No. 91331-5 Madsen, C.J., dissenting protects when it stated that "while it may not always be simple for members of the jury to obey the instruction that they disregard an incriminating inference, there does not exist the overwhelming probability of their inability to do so that is the foundation of Bruton's exception to the general rule." Id. at 208 . | 1 | 5 |
State v. Flowers-Roscoegreen1 sentence2015See Wynn, 126 Wn. | 1 | 1 |
United States v. Figueroa-Cartagenagreen2 sentences2014Ed. 2d 555 (2011) (holding that the Bruton rule does not apply to non-testimonial statements). 88 United States v. Figueroa-Cartagena. 612 F.3d 69, 85 (1st Cir. 2010) (quoting Whorton v. Bocktino. 549 U.S. 406 , 420, 127 S. Ct. 1173 (2007)). 89 State v. Greiff. 141 Wn.2d 910, 929 , 10 P.3d 390 (2000). 30 No. 69005-1-1/31 Here, there is not an accumulation of several errors. 2014Ed. 2d 555 (2011) (holding that the Bruton rule does not apply to non-testimonial statements). 88 United States v. Figueroa-Cartagena. 612 F.3d 69, 85 (1st Cir. 2010) (quoting Whorton v. Bocktino. 549 U.S. 406 , 420, 127 S. Ct. 1173 (2007)). 89 State v. Greiff. 141 Wn.2d 910, 929 , 10 P.3d 390 (2000). 30 No. 69005-1-1/31 Here, there is not an accumulation of several errors. | 1 | 1 |
| Schlesinger v. Reservists Committee to Stop the Wargreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
United States v. Gonzalezgreen2 sentences2016But see United States v. Gonzalez, 183 F.3d 1315, 1322 (11th Cir. 1999) (holding that a redacted confession implicating a precise number of the confessor’s codefendants violated the confrontation clause); United States v. Vejar-Urias, 165 F.3d 337, 340 (5th Cir. 1999) (holding that use of the term “ ‘someone’ ” violated the confrontation clause). ¶14 Neither the Supreme Court nor this court has addressed this question, but our Court of Appeals has. 2016But see United States v. Gonzalez, 183 F.3d 1315, 1322 (11th Cir. 1999) (holding that a redacted confession implicating a precise number of the confessor’s codefendants violated the confrontation clause); United States v. Vejar-Urias, 165 F.3d 337, 340 (5th Cir. 1999) (holding that use of the term “ ‘someone’ ” violated the confrontation clause). ¶14 Neither the Supreme Court nor this court has addressed this question, but our Court of Appeals has. | 1 | 1 |
| Case | Cited | Years |
|---|---|---|
State v. Wilcoxon
green
2 sentences2017To that end, Dawson's statement that Hamilton claimed a knife was present was useful testimony for the defense. 6 See State v. Wilcoxon, 185 Wn.2d 324 , 373 P.3d 224 , cert. denied 137 S. Ct. 580 (2016) (statement by one defendant to other acquaintance not testimonial hearsay despite Bruton doctrine). 7 Interestingly, when the prosecutor warned of possible Bruton problems with the phrasing of a defense question, Limpert's counsel immediately rephrased his questions in a manner that expressly brought the confrontation problem to the fore. 2017To that end, Dawson's statement that Hamilton claimed a knife was present was useful testimony for the defense. 6 See State v. Wilcoxon, 185 Wn.2d 324 , 373 P.3d 224 , cert. denied 137 S. Ct. 580 (2016) (statement by one defendant to other acquaintance not testimonial hearsay despite Bruton doctrine). 7 Interestingly, when the prosecutor warned of possible Bruton problems with the phrasing of a defense question, Limpert's counsel immediately rephrased his questions in a manner that expressly brought the confrontation problem to the fore. | 3 | 2016–2017 |
Whorton v. Bockting
green
2 sentences2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l 2016If it is not, the Confrontation Clause ‘has no application.’ ” (quoting Whorton, 549 U.S. at 420 )); United States v. Berrios, 676 F.3d 118, 128 (3d Cir. 2012) (“[Because Bruton is no more than a by-product of the Confrontation Clause, the Court’s holdings in Davis and Crawford likewise limit Bruton to testimonial statements.”); United States v. Dargan, 738 F.3d 643, 651 (4th Cir. 2013) (“Bruton is simply irrelevant in the context of nontestimonial statements.”); United States v. Johnson, 581 F.3d 320, 326 (6th Cir. 2009) (“Because it is premised on the Confrontation Clause, the Bruton rule, l | 3 | 2014–2016 |
State v. Vannoy
green
2 sentences2014Perez relies on Bruton v. United States, for the proposition that "when two or more defendants are tried in a joint proceeding, an out-of-court statement of one which inculpates another may not be admitted in evidence when the maker of the statement does not testify at trial, for the effect would be a denial of the right [to] confrontation."84 He also cites State v. Vannoy to argue that if a codefendant's confession contains the pronoun "we," and a jury could readily conclude that the "we" includes the defendant, the Bruton rule applies.85 While these general rules are true, these cases were d 2014Perez relies on Bruton v. United States, for the proposition that "when two or more defendants are tried in a joint proceeding, an out-of-court statement of one which inculpates another may not be admitted in evidence when the maker of the statement does not testify at trial, for the effect would be a denial of the right [to] confrontation."84 He also cites State v. Vannoy to argue that if a codefendant's confession contains the pronoun "we," and a jury could readily conclude that the "we" includes the defendant, the Bruton rule applies.85 While these general rules are true, these cases were d | 3 | 2014–2014 |
Delli Paoli v. United States
red
2 sentences2016The Bruton doctrine developed to address the harmful effect of putting evidence, inadmissible against a codefendant, before the jury in a joint trial, while Roberts, 8 Crawford, and Davis deal with the proper means of assessing reliability in determining what evidence may be admitted directly against the defendant without violating the confrontation clause. ¶41 Bruton finds its beginnings in Delli Paoli v. United States, 352 U.S. 232 , 77 S. Ct. 294 , 1 L. 2016The Bruton doctrine developed to address the harmful effect of putting evidence, inadmissible against a codefendant, before the jury in a joint trial, while Roberts, 8 Crawford, and Davis deal with the proper means of assessing reliability in determining what evidence may be admitted directly against the defendant without violating the confrontation clause. ¶41 Bruton finds its beginnings in Delli Paoli v. United States, 352 U.S. 232 , 77 S. Ct. 294 , 1 L. | 2 | 2016–2016 |
State v. Lui
green
2 sentences2016A sampling of the remaining evidence included (1) DNA evidence linking the defendant to the murder, (2) evidence that a bloodhound led investigators directly to the defendant, (3) numerous inconsistencies in the testimony of the defendant, detracting from his credibility, and (4) “evidence suggesting that [the victim] had died before she could dress or put on her customary makeup; evidence suggesting that [she] had been dressed and her bags packed by ‘somebody who doesn’t know anything about women.’ ” Id. ¶71 In addition to this court’s harmless error jurisprudence, a look back at Harrington, 2016A sampling of the remaining evidence included (1) DNA evidence linking the defendant to the murder, (2) evidence that a bloodhound led investigators directly to the defendant, (3) numerous inconsistencies in the testimony of the defendant, detracting from his credibility, and (4) “evidence suggesting that [the victim] had died before she could dress or put on her customary makeup; evidence suggesting that [she] had been dressed and her bags packed by ‘somebody who doesn’t know anything about women.’ ” Id. ¶71 In addition to this court’s harmless error jurisprudence, a look back at Harrington, | 2 | 2014–2016 |
Parker v. Randolph
red
2 sentences2016The court reiterated the harm against which Bruton protects when it stated that “while it may not always be simple for members of the jury to obey the instruction that they disregard an incriminating inference, there does not exist the overwhelming probability of their inability to do so that is the foundation of Bruton’s exception to the general rule.” Id. at 208 . ¶48 In the same year, the Court decided Cruz , overruling Parker v. Randolph, 442 U.S. 62 , 99 S. Ct. 2132 , 60 L. 2016The court reiterated the harm against which Bruton protects when it stated that “while it may not always be simple for members of the jury to obey the instruction that they disregard an incriminating inference, there does not exist the overwhelming probability of their inability to do so that is the foundation of Bruton’s exception to the general rule.” Id. at 208 . ¶48 In the same year, the Court decided Cruz , overruling Parker v. Randolph, 442 U.S. 62 , 99 S. Ct. 2132 , 60 L. | 2 | 2016–2016 |
State v. Medina
neutral
2 sentences2014The Medina court concluded that no Bruton violation occurred because the statements were redacted in such a way that it became impossible to track the activities of any particular “guy” among the several involved. 112 Wn. 2014The Medina court concluded that no Bruton violation occurred because the statements were redacted in such a way that it became impossible to track the activities of any particular " guy" among the several involved. 112 Wn. | 2 | 2014–2014 |
State v. Craig
green
2 sentences2008State v. Craig, 82 Wn.2d 777, 788 , 514 P.2d 151 (1973). ¶34 Here, Johnson’s statements were introduced through his testimony, not a confession. 2008State v. Craig, 82 Wn.2d 777, 788 , 514 P.2d 151 (1973). ¶34 Here, Johnson’s statements were introduced through his testimony, not a confession. | 2 | 2008–2008 |
State Of Washington, V Justin Moses And Aimee Moses
green
2 sentences2017However, “[s]tatements that do not incriminate a codefendant are not subject to the Bruton rule.” Moses, 193 Wn. 2017However, “[s]tatements that do not incriminate a codefendant are not subject to the Bruton rule.” Moses, 193 Wn. | 1 | 2017–2017 |
Hernandez v. Tex. Bd. of Pardons & Paroles
green
1 sentence2017To that end, Dawson's statement that Hamilton claimed a knife was present was useful testimony for the defense. 6 See State v. Wilcoxon, 185 Wn.2d 324 , 373 P.3d 224 , cert. denied 137 S. Ct. 580 (2016) (statement by one defendant to other acquaintance not testimonial hearsay despite Bruton doctrine). 7 Interestingly, when the prosecutor warned of possible Bruton problems with the phrasing of a defense question, Limpert's counsel immediately rephrased his questions in a manner that expressly brought the confrontation problem to the fore. | 1 | 2017–2017 |
State v. Dent
green
2 sentences2016State v. Dent, 123 Wn.2d 467, 487 , 869 P.2d 392 (1994). ¶38 We have stated that a nontestifying codefendant’s statement violates the confrontation clause unless certain criteria are met when redacting the statement. 2016State v. Dent, 123 Wn.2d 467, 487 , 869 P.2d 392 (1994). ¶38 We have stated that a nontestifying codefendant’s statement violates the confrontation clause unless certain criteria are met when redacting the statement. | 1 | 2016–2016 |
State v. McFarland
green
1 sentence2015McFarland, 127 Wn.2d at 334-35 . 31 Although we addressed an issue related to Wynn’s statement in the second appeal, the challenge in the appeal was to a different part of Wynn’s statement and was not a Bruton issue. | 1 | 2015–2015 |
| Crawford v. Washington green | 1 | 2014–2014 |
| United States v. Smalls green | 1 | 2014–2014 |
| Davis v. Washington green | 1 | 2014–2014 |
| Abulkhair v. Reuben Banks neutral | 1 | 2014–2014 |
Driver v. Landers
neutral
2 sentences2014United States v. Smalls, 605 F.3d 765 , 768 n.2 (10th Cir. 2010) (stating that "the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements."); United States v. Johnson. 581 F.3d 320, 326 (6th Cir. 2009), cert, denied. 560 U.S. 966 (2010) (stating that "[b]ecause it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements"); People v. Arceo, 195 Cal. App. 4th 556, 574-75 , 125 Cal. Rptr. 3d 436 , cert, denied. 132 S. Ct. 851 , 181 L. 2014United States v. Smalls, 605 F.3d 765 , 768 n.2 (10th Cir. 2010) (stating that "the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements."); United States v. Johnson. 581 F.3d 320, 326 (6th Cir. 2009), cert, denied. 560 U.S. 966 (2010) (stating that "[b]ecause it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements"); People v. Arceo, 195 Cal. App. 4th 556, 574-75 , 125 Cal. Rptr. 3d 436 , cert, denied. 132 S. Ct. 851 , 181 L. | 1 | 2014–2014 |
| State v. Greiff green | 1 | 2014–2014 |
| Harris v. Wittman green | 1 | 2014–2014 |
People v. Arceo
green
2 sentences2014United States v. Smalls, 605 F.3d 765 , 768 n.2 (10th Cir. 2010) (stating that "the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements."); United States v. Johnson. 581 F.3d 320, 326 (6th Cir. 2009), cert, denied. 560 U.S. 966 (2010) (stating that "[b]ecause it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements"); People v. Arceo, 195 Cal. App. 4th 556, 574-75 , 125 Cal. Rptr. 3d 436 , cert, denied. 132 S. Ct. 851 , 181 L. 2014United States v. Smalls, 605 F.3d 765 , 768 n.2 (10th Cir. 2010) (stating that "the Bruton rule, like the Confrontation Clause upon which it is premised, does not apply to nontestimonial hearsay statements."); United States v. Johnson. 581 F.3d 320, 326 (6th Cir. 2009), cert, denied. 560 U.S. 966 (2010) (stating that "[b]ecause it is premised on the Confrontation Clause, the Bruton rule, like the Confrontation Clause itself, does not apply to nontestimonial statements"); People v. Arceo, 195 Cal. App. 4th 556, 574-75 , 125 Cal. Rptr. 3d 436 , cert, denied. 132 S. Ct. 851 , 181 L. | 1 | 2014–2014 |
| State v. Greiff green | 1 | 2014–2014 |
| State v. Larry green | 1 | 2011–2011 |
| State v. Larry green | 1 | 2011–2011 |
| State v. Hieb green | 1 | 2001–2001 |
| State v. Wheeler green | 1 | 1985–1985 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.