Bruton error (Mississippi) · Go Syfert
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Bruton error in Mississippi

12 Mississippi opinions name it 2 courts 1986–2025 1 in the last five years

The cases below were cited by Mississippi 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.

Followed or applied (7)

CaseFollowedCited
Haynes v. Stategreen
miss · 2006 · cited in 2 Mississippi opinions naming this issue, 2006–2008
2 sentences

2008See Haynes v. State, 934 So.2d 983, 991 (Miss.2006) (This Court has held "errors involving a violation of an accused's constitutional rights may be deemed harmless beyond a reasonable doubt where the weight of the evidence against the accused is overwhelming.") ¶ 33.

2008See Haynes v. State, 934 So.2d 983, 991 (Miss.2006) (This Court has held "errors involving a violation of an accused's constitutional rights may be deemed harmless beyond a reasonable doubt where the weight of the evidence against the accused is overwhelming.") ¶ 33.

22
Lee v. Illinoisgreen
scotus · 1986 · cited in 2 Mississippi opinions naming this issue, 1986–1987
2 sentences

1986Nor does the natural "motivation to shift the blame onto others," recognized by the Bruton Court to render the incriminating statements of codefendants "inevitably suspect." id., at 136 , 20 L.Ed.2d at 476 , 88 S.Ct. at 1620 , require application of the Bruton rule when the incriminated defendant has corroborated his defendant's statements by heaping blame onto himself. 442 U.S. 72 , 99 S.Ct. 2132 , 60 L.Ed.2d 723 , but see Lee v. Illinois, ___ U.S. ___, 106 S.Ct. 2056 , 90 L.Ed.2d 514 (1986) [subjects upon which the two confessions did not "interlock" could not be characterized as irrelevant

1986Nor does the natural "motivation to shift the blame onto others," recognized by the Bruton Court to render the incriminating statements of codefendants "inevitably suspect." id., at 136 , 20 L.Ed.2d at 476 , 88 S.Ct. at 1620 , require application of the Bruton rule when the incriminated defendant has corroborated his defendant's statements by heaping blame onto himself. 442 U.S. 72 , 99 S.Ct. 2132 , 60 L.Ed.2d 723 , but see Lee v. Illinois, ___ U.S. ___, 106 S.Ct. 2056 , 90 L.Ed.2d 514 (1986) [subjects upon which the two confessions did not "interlock" could not be characterized as irrelevant

12
Veasley v. Stategreen
miss · 1999 · cited in 1 Mississippi opinions naming this issue, 2025–2025
2 sentences

2025Also, in Veasley v. State, 735 So. 2d 432, 437 (Miss. 1999) (alterations in original) (emphasis added) (citations omitted), this Court explained how we should consider the concept of harmless error and ruled: 2 The Court recognized that Bruton v. United States, 391 U.S. 123 , 88 S. Ct. 1620 , 20 L.

2025Also, in Veasley v. State, 735 So. 2d 432, 437 (Miss. 1999) (alterations in original) (emphasis added) (citations omitted), this Court explained how we should consider the concept of harmless error and ruled: 2 The Court recognized that Bruton v. United States, 391 U.S. 123 , 88 S. Ct. 1620 , 20 L.

11
Jones v. Stategreen
miss · 1984 · cited in 1 Mississippi opinions naming this issue, 1986–1986
2 sentences

1986Jones v. State, 461 So.2d 686, 701 (Miss. 1984).

1986Jones v. State, 461 So.2d 686, 701 (Miss. 1984).

11
United States v. James Massa, United States of America v. Duane Skinnergreen
ca8 · 1984 · cited in 1 Mississippi opinions naming this issue, 1986–1986
2 sentences

1986See, e.g., United States v. Smith, 792 F.2d 441, 443 (4th Cir.1986); United States v. Palow, 777 F.2d 52, 57 (1st Cir.1986); United States v. Massa, 740 F.2d 629, 639 (8th Cir.1984).

1986See, e.g., United States v. Smith, 792 F.2d 441, 443 (4th Cir.1986); United States v. Palow, 777 F.2d 52, 57 (1st Cir.1986); United States v. Massa, 740 F.2d 629, 639 (8th Cir.1984).

11
United States v. Robert S. Palow, United States of America v. Paul C. Alvaradogreen
ca1 · 1985 · cited in 1 Mississippi opinions naming this issue, 1986–1986
2 sentences

1986See, e.g., United States v. Smith, 792 F.2d 441, 443 (4th Cir.1986); United States v. Palow, 777 F.2d 52, 57 (1st Cir.1986); United States v. Massa, 740 F.2d 629, 639 (8th Cir.1984).

1986See, e.g., United States v. Smith, 792 F.2d 441, 443 (4th Cir.1986); United States v. Palow, 777 F.2d 52, 57 (1st Cir.1986); United States v. Massa, 740 F.2d 629, 639 (8th Cir.1984).

11
United States v. Robert Preston Smith, United States of America v. Robert Jackson Eurygreen
ca4 · 1986 · cited in 1 Mississippi opinions naming this issue, 1986–1986
2 sentences

1986See, e.g., United States v. Smith, 792 F.2d 441, 443 (4th Cir.1986); United States v. Palow, 777 F.2d 52, 57 (1st Cir.1986); United States v. Massa, 740 F.2d 629, 639 (8th Cir.1984).

1986See, e.g., United States v. Smith, 792 F.2d 441, 443 (4th Cir.1986); United States v. Palow, 777 F.2d 52, 57 (1st Cir.1986); United States v. Massa, 740 F.2d 629, 639 (8th Cir.1984).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Mississippi. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Bruton v. United States green
scotus · 1968
2 sentences

1986Nor does the natural "motivation to shift the blame onto others," recognized by the Bruton Court to render the incriminating statements of codefendants "inevitably suspect." id., at 136 , 20 L.Ed.2d at 476 , 88 S.Ct. at 1620 , require application of the Bruton rule when the incriminated defendant has corroborated his defendant's statements by heaping blame onto himself. 442 U.S. 72 , 99 S.Ct. 2132 , 60 L.Ed.2d 723 , but see Lee v. Illinois, ___ U.S. ___, 106 S.Ct. 2056 , 90 L.Ed.2d 514 (1986) [subjects upon which the two confessions did not "interlock" could not be characterized as irrelevant

1986Nor does the natural "motivation to shift the blame onto others," recognized by the Bruton Court to render the incriminating statements of codefendants "inevitably suspect." id., at 136 , 20 L.Ed.2d at 476 , 88 S.Ct. at 1620 , require application of the Bruton rule when the incriminated defendant has corroborated his defendant's statements by heaping blame onto himself. 442 U.S. 72 , 99 S.Ct. 2132 , 60 L.Ed.2d 723 , but see Lee v. Illinois, ___ U.S. ___, 106 S.Ct. 2056 , 90 L.Ed.2d 514 (1986) [subjects upon which the two confessions did not "interlock" could not be characterized as irrelevant

41986–2025
Brown v. United States green
scotus · 1973
2 sentences

2025The United States Supreme Court has explicitly “reject[ed] the notion that a Bruton error[2] can never be harmless. ‘[A] defendant is entitled to a fair trial but not a perfect one,’ for there are no perfect trials.” Brown v. United States, 411 U.S. 223, 231-32 , 93 S. Ct. 1565, 1570 , 36 L.

2025The United States Supreme Court has explicitly “reject[ed] the notion that a Bruton error[2] can never be harmless. ‘[A] defendant is entitled to a fair trial but not a perfect one,’ for there are no perfect trials.” Brown v. United States, 411 U.S. 223, 231-32 , 93 S. Ct. 1565, 1570 , 36 L.

42004–2025
Richardson v. Marsh green
scotus · 1987
2 sentences

2004"Where the co-defendant's statements do not facially implicate the defendant in the crime, there is no Bruton error." Richardson, 481 U.S. at 208-09 , 107 S.Ct. 1702 . ¶ 43.

2004"Where the co-defendant's statements do not facially implicate the defendant in the crime, there is no Bruton error." Richardson, 481 U.S. at 208-09 , 107 S.Ct. 1702 . ¶ 43.

42001–2005
Clark v. State green
miss · 2004
2 sentences

2008Clark followed Brown v. United States , which held that admission into evidence of a statement made by a non-testifying codefendant — a Bruton error — is harmless where "[t]he testimony erroneously admitted was merely cumulative of other overwhelming and largely uncontroverted evidence properly before the jury." Brown, 411 U.S. at 231 , 93 S.Ct. 1565 ; Clark, 891 So.2d at 141 .

2008Clark followed Brown v. United States , which held that admission into evidence of a statement made by a non-testifying codefendant — a Bruton error — is harmless where "[t]he testimony erroneously admitted was merely cumulative of other overwhelming and largely uncontroverted evidence properly before the jury." Brown, 411 U.S. at 231 , 93 S.Ct. 1565 ; Clark, 891 So.2d at 141 .

22006–2008
Crawford v. Washington green
scotus · 2004
2 sentences

2005Bynum further argues that this Court should consider his appeal in the light of Crawford v. Washington, 541 U.S. 36 , 124 S.Ct. 1354 , 158 L.Ed.2d 177 (2004).

2005Bynum further argues that this Court should consider his appeal in the light of Crawford v. Washington, 541 U.S. 36 , 124 S.Ct. 1354 , 158 L.Ed.2d 177 (2004).

12005–2005
Ohio v. Roberts red
scotus · 1980
2 sentences

1997Ohio v. Roberts, 448 U.S. 56, 66 , . . . (1980).

1997Ohio v. Roberts, 448 U.S. 56, 66 , . . . (1980).

11997–1997
Brown v. State green
miss · 1976
2 sentences

1986After eight years of experience with the Bruton rule, this Court in Brown v. State, 340 So.2d 718 (Miss. 1976) announced a procedural rule which, in pertinent part, provides as follows: [I]n such cases, the prosecution should not offer, and the trial judge should not admit, in evidence, incriminating statements of a co-defendant (implicating the defendant) during the state's case-in-chief, since it could not be known whether the co-defendant would testify after the state rested.

1986After eight years of experience with the Bruton rule, this Court in Brown v. State, 340 So.2d 718 (Miss. 1976) announced a procedural rule which, in pertinent part, provides as follows: [I]n such cases, the prosecution should not offer, and the trial judge should not admit, in evidence, incriminating statements of a co-defendant (implicating the defendant) during the state's case-in-chief, since it could not be known whether the co-defendant would testify after the state rested.

11986–1986
Parker v. Randolph red
scotus · 1979
2 sentences

1986Nor does the natural "motivation to shift the blame onto others," recognized by the Bruton Court to render the incriminating statements of codefendants "inevitably suspect." id., at 136 , 20 L.Ed.2d at 476 , 88 S.Ct. at 1620 , require application of the Bruton rule when the incriminated defendant has corroborated his defendant's statements by heaping blame onto himself. 442 U.S. 72 , 99 S.Ct. 2132 , 60 L.Ed.2d 723 , but see Lee v. Illinois, ___ U.S. ___, 106 S.Ct. 2056 , 90 L.Ed.2d 514 (1986) [subjects upon which the two confessions did not "interlock" could not be characterized as irrelevant

1986Nor does the natural "motivation to shift the blame onto others," recognized by the Bruton Court to render the incriminating statements of codefendants "inevitably suspect." id., at 136 , 20 L.Ed.2d at 476 , 88 S.Ct. at 1620 , require application of the Bruton rule when the incriminated defendant has corroborated his defendant's statements by heaping blame onto himself. 442 U.S. 72 , 99 S.Ct. 2132 , 60 L.Ed.2d 723 , but see Lee v. Illinois, ___ U.S. ___, 106 S.Ct. 2056 , 90 L.Ed.2d 514 (1986) [subjects upon which the two confessions did not "interlock" could not be characterized as irrelevant

11986–1986

Statutes the citing opinions construe

MS § Miss. Code Ann. § 97-3-19 (5) MS § Miss. Code Ann. § 97-3-7 (3)

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.

Where else courts name it

GA 133 (1973–2026) CA 129 (1969–2026) NY 107 (1968–2024) PA 87 (1973–2026) IL 69 (1969–2019) TN 66 (1969–2025) OH 48 (1978–2026) MA 46 (1969–2019) FL 41 (1969–2026) NC 24 (1971–2023) OK 22 (1973–2020) IN 22 (1971–2016) WA 21 (1976–2026) MD 21 (1972–2022) TX 19 (1970–2013) LA 15 (1969–2012) KY 14 (1973–2011) MI 14 (1971–2016) DC 13 (1974–2024) AZ 13 (1969–2014) KS 13 (1978–2006) NV 12 (1970–2020) MS 12 (1986–2025) CT 11 (1970–2018) NJ 10 (1971–2021) NM 8 (1976–2014) ME 8 (1972–2013) AR 8 (1975–2004) AK 7 (1973–2017) AL 7 (1983–1996) SC 7 (1976–2017) IA 7 (1981–2015) OR 6 (1990–2025) ID 6 (1985–2025) WI 5 (1978–2019) HI 4 (1977–1993) UT 4 (1987–2021) MT 4 (1977–1999) VA 4 (1997–2023) RI 3 (1971–2025) MO 3 (1989–1997) DE 3 (1994–2018) VI 2 (2012–2012) SD 2 (1993–2009) NH 2 (1975–2002)

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.

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