10 New Jersey opinions name it 2 courts 1971–2021 1 in the last five years
The cases below were cited by New Jersey 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 |
|---|---|---|
State v. Corsigreen1 sentence2021See State v. Corsi, 86 N.J. 172, 176-77 (1981) (describing severance and other options to avoid Bruton issue). 17 A-1623-20 there cannot be "an effective deletion [from a defendant's statement] of all references to the codefendants without prejudice to the confessing defendant"). | 1 | 1 |
State v. Buonadonnagreen1 sentence2021See Buonadonna, 122 N.J. at 39 (acknowledging "the right to confront opposing witnesses or obtain severance of a trial is subject to tactical considerations that could lead a reasonable defendant, in consultation with counsel, to waive the right"); Pressler & Verniero, Current N.J. | 1 | 1 |
Schneble v. Floridagreen2 sentences2019See Schneble v. Florida, 405 U.S. 427, 430 (1972) (observing that "[t]he mere finding of a violation of the Bruton rule . . . does not automatically require reversal of the ensuing criminal conviction," where "the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the codefendant's admission is so insignificant by comparison."). 2019See Schneble v. Florida, 405 U.S. 427, 430 (1972) (observing that "[t]he mere finding of a violation of the Bruton rule . . . does not automatically require reversal of the ensuing criminal conviction," where "the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the codefendant's admission is so insignificant by comparison."). | 1 | 1 |
Gray v. Marylandgreen2 sentences2011Therefore, although “Richardson placed outside the scope of Bruton’s rule those statements that incriminate inferentially!,]” and “the jury must use inference to connect the statement in this redacted confession with the defendant!,]” Gray ruled that “inference pure and simple cannot make the critical difference!.]” Id. at 195 , 118 S.Ct. at 1156 , 140 L.Ed.2d at 302 . 2011Therefore, although “Richardson placed outside the scope of Bruton’s rule those statements that incriminate inferentially!,]” and “the jury must use inference to connect the statement in this redacted confession with the defendant!,]” Gray ruled that “inference pure and simple cannot make the critical difference!.]” Id. at 195 , 118 S.Ct. at 1156 , 140 L.Ed.2d at 302 . | 1 | 1 |
Delaware v. Van Arsdallgreen2 sentences1991See, e.g., Delaware v. Van Arsdall, 475 U.S. 673, 682 , 106 S.Ct. 1431, 1436-37 , 89 L.Ed.2d 674, 685 (1986) (Bruton error may be harmless); Brown v. United States, 411 U.S. 223 , 93 S.Ct. 1565 , 36 L.Ed.2d 208 (1973) (same); see also Solomon v. Harris, 749 F. 2d 1, 3 (2d Cir.1984) (failure to raise Bruton objection did not undermine defense strategy and therefore was harmless), cert. denied, 470 U.S. 1087 , 105 S.Ct. 1851 , 85 L.Ed.2d 149 (1985); United States *43 ex rel. 1991See, e.g., Delaware v. Van Arsdall, 475 U.S. 673, 682 , 106 S.Ct. 1431, 1436-37 , 89 L.Ed.2d 674, 685 (1986) (Bruton error may be harmless); Brown v. United States, 411 U.S. 223 , 93 S.Ct. 1565 , 36 L.Ed.2d 208 (1973) (same); see also Solomon v. Harris, 749 F. 2d 1, 3 (2d Cir.1984) (failure to raise Bruton objection did not undermine defense strategy and therefore was harmless), cert. denied, 470 U.S. 1087 , 105 S.Ct. 1851 , 85 L.Ed.2d 149 (1985); United States *43 ex rel. | 1 | 1 |
United States Ex Rel. Hanrahan v. Thieretgreen2 sentences1991Hanrahan v. Thieret, 695 F.Supp. 372, 388 (N.D.Ill. 1988) (Bruton error harmless because it did not affect trial outcome), vacated and remanded on other grounds sub nom. 1991Hanrahan v. Thieret, 695 F.Supp. 372, 388 (N.D.Ill. 1988) (Bruton error harmless because it did not affect trial outcome), vacated and remanded on other grounds sub nom. | 1 | 1 |
Nathan Solomon v. David Harris, Warden of Green Haven Correctional Facility, and Robert Abrams, Attorney General of the State of New Yorkgreen2 sentences1991See, e.g., Delaware v. Van Arsdall, 475 U.S. 673, 682 , 106 S.Ct. 1431, 1436-37 , 89 L.Ed.2d 674, 685 (1986) (Bruton error may be harmless); Brown v. United States, 411 U.S. 223 , 93 S.Ct. 1565 , 36 L.Ed.2d 208 (1973) (same); see also Solomon v. Harris, 749 F. 2d 1, 3 (2d Cir.1984) (failure to raise Bruton objection did not undermine defense strategy and therefore was harmless), cert. denied, 470 U.S. 1087 , 105 S.Ct. 1851 , 85 L.Ed.2d 149 (1985); United States *43 ex rel. 1991See, e.g., Delaware v. Van Arsdall, 475 U.S. 673, 682 , 106 S.Ct. 1431, 1436-37 , 89 L.Ed.2d 674, 685 (1986) (Bruton error may be harmless); Brown v. United States, 411 U.S. 223 , 93 S.Ct. 1565 , 36 L.Ed.2d 208 (1973) (same); see also Solomon v. Harris, 749 F. 2d 1, 3 (2d Cir.1984) (failure to raise Bruton objection did not undermine defense strategy and therefore was harmless), cert. denied, 470 U.S. 1087 , 105 S.Ct. 1851 , 85 L.Ed.2d 149 (1985); United States *43 ex rel. | 1 | 1 |
People v. Shellgreen2 sentences1991In People v. Shell, 152 A.D.2d 609 , 543 N.Y.S.2d 510 , appeal denied, 74 N.Y.2d 899 , 548 N.Y.S.2d 432 , 547 N.E. 2d 959 (1989), trial counsel refused the court’s offer to hold a Bruton hearing because he wanted the codefendant’s statements introduced in evidence. 1991In People v. Shell, 152 A.D.2d 609 , 543 N.Y.S.2d 510 , appeal denied, 74 N.Y.2d 899 , 548 N.Y.S.2d 432 , 547 N.E. 2d 959 (1989), trial counsel refused the court’s offer to hold a Bruton hearing because he wanted the codefendant’s statements introduced in evidence. | 1 | 1 |
Brodis v. Detroit Board of Educationgreen2 sentences1991See, e.g., Delaware v. Van Arsdall, 475 U.S. 673, 682 , 106 S.Ct. 1431, 1436-37 , 89 L.Ed.2d 674, 685 (1986) (Bruton error may be harmless); Brown v. United States, 411 U.S. 223 , 93 S.Ct. 1565 , 36 L.Ed.2d 208 (1973) (same); see also Solomon v. Harris, 749 F. 2d 1, 3 (2d Cir.1984) (failure to raise Bruton objection did not undermine defense strategy and therefore was harmless), cert. denied, 470 U.S. 1087 , 105 S.Ct. 1851 , 85 L.Ed.2d 149 (1985); United States *43 ex rel. 1991See, e.g., Delaware v. Van Arsdall, 475 U.S. 673, 682 , 106 S.Ct. 1431, 1436-37 , 89 L.Ed.2d 674, 685 (1986) (Bruton error may be harmless); Brown v. United States, 411 U.S. 223 , 93 S.Ct. 1565 , 36 L.Ed.2d 208 (1973) (same); see also Solomon v. Harris, 749 F. 2d 1, 3 (2d Cir.1984) (failure to raise Bruton objection did not undermine defense strategy and therefore was harmless), cert. denied, 470 U.S. 1087 , 105 S.Ct. 1851 , 85 L.Ed.2d 149 (1985); United States *43 ex rel. | 1 | 1 |
Solomon v. Harrisgreen2 sentences1991See, e.g., Delaware v. Van Arsdall, 475 U.S. 673, 682 , 106 S.Ct. 1431, 1436-37 , 89 L.Ed.2d 674, 685 (1986) (Bruton error may be harmless); Brown v. United States, 411 U.S. 223 , 93 S.Ct. 1565 , 36 L.Ed.2d 208 (1973) (same); see also Solomon v. Harris, 749 F. 2d 1, 3 (2d Cir.1984) (failure to raise Bruton objection did not undermine defense strategy and therefore was harmless), cert. denied, 470 U.S. 1087 , 105 S.Ct. 1851 , 85 L.Ed.2d 149 (1985); United States *43 ex rel. 1991See, e.g., Delaware v. Van Arsdall, 475 U.S. 673, 682 , 106 S.Ct. 1431, 1436-37 , 89 L.Ed.2d 674, 685 (1986) (Bruton error may be harmless); Brown v. United States, 411 U.S. 223 , 93 S.Ct. 1565 , 36 L.Ed.2d 208 (1973) (same); see also Solomon v. Harris, 749 F. 2d 1, 3 (2d Cir.1984) (failure to raise Bruton objection did not undermine defense strategy and therefore was harmless), cert. denied, 470 U.S. 1087 , 105 S.Ct. 1851 , 85 L.Ed.2d 149 (1985); United States *43 ex rel. | 1 | 1 |
State v. Haskellgreen2 sentences1985As Judge Dreier observed in State v. Haskell, 195 N.J.Super. 235, 237 (App.Div.), certif. granted 99 N.J. 198 (1984) (argued March 18, 1985), New Jersey’s appellate courts have never condoned or adopted the so-called “interlocking confessions” exception of Parker v. Randolph as a matter of State constitutional or procedural law. 1985As Judge Dreier observed in State v. Haskell, 195 N.J.Super. 235, 237 (App.Div.), certif. granted 99 N.J. 198 (1984) (argued March 18, 1985), New Jersey’s appellate courts have never condoned or adopted the so-called “interlocking confessions” exception of Parker v. Randolph as a matter of State constitutional or procedural law. | 1 | 1 |
United States v. Charles Venere and Robert Anthony Perrottagreen2 sentences1985As the court noted in United States v. Venere, 416 F.2d 144, 149 (5th Cir.1969), the Bruton rule addressed “the inability of the traditional limiting instructions to assure the differentiation by the jury between the impact of the unsworn statement on the defendant and on the nonconfessing co-defendant.” The Fifth Circuit concluded that any danger was “greatly attenuated by the circumstance that a jury was waived.” Ibid. 1985As the court noted in United States v. Venere, 416 F.2d 144, 149 (5th Cir.1969), the Bruton rule addressed “the inability of the traditional limiting instructions to assure the differentiation by the jury between the impact of the unsworn statement on the defendant and on the nonconfessing co-defendant.” The Fifth Circuit concluded that any danger was “greatly attenuated by the circumstance that a jury was waived.” Ibid. | 1 | 1 |
State v. Gardnergreen2 sentences1984State v. Gardner, 54 N.J. 37, 42 (1969). 1984State v. Gardner, 54 N.J. 37, 42 (1969). | 1 | 1 |
Janiec v. McCorklegreen1 sentence1971In effect, defendant challenges the trial court's reasons for denying post-conviction relief, but it should be noted that "appeals are taken from judgments or orders and not from reasons assigned." Janiec v. McCorkle, 52 N.J. | 1 | 1 |
State v. MacOngreen1 sentence1971That it came voluntarily from Nathaniel instead of being wrung from him on cross-examination shows only that cross-examination was unnecessary and not that it was unavailable. [*] We hold, therefore, that John suffered no deprivation of his constitutional right of confrontation which made the admission of Nathaniel's confession constitutionally invalid as to John. [*] [ 415 F. 2d at 571-573 ] However, even if Wade were not entirely controlling, we find that, in light of the record, any Bruton error was "harmless beyond a reasonable doubt." Harrington v. California, 395 U.S. 250 , 89 S.Ct. 1726 | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in New Jersey. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Brown v. United States
green
2 sentences1991See, e.g., Delaware v. Van Arsdall, 475 U.S. 673, 682 , 106 S.Ct. 1431, 1436-37 , 89 L.Ed.2d 674, 685 (1986) (Bruton error may be harmless); Brown v. United States, 411 U.S. 223 , 93 S.Ct. 1565 , 36 L.Ed.2d 208 (1973) (same); see also Solomon v. Harris, 749 F. 2d 1, 3 (2d Cir.1984) (failure to raise Bruton objection did not undermine defense strategy and therefore was harmless), cert. denied, 470 U.S. 1087 , 105 S.Ct. 1851 , 85 L.Ed.2d 149 (1985); United States *43 ex rel. 1991See, e.g., Delaware v. Van Arsdall, 475 U.S. 673, 682 , 106 S.Ct. 1431, 1436-37 , 89 L.Ed.2d 674, 685 (1986) (Bruton error may be harmless); Brown v. United States, 411 U.S. 223 , 93 S.Ct. 1565 , 36 L.Ed.2d 208 (1973) (same); see also Solomon v. Harris, 749 F. 2d 1, 3 (2d Cir.1984) (failure to raise Bruton objection did not undermine defense strategy and therefore was harmless), cert. denied, 470 U.S. 1087 , 105 S.Ct. 1851 , 85 L.Ed.2d 149 (1985); United States *43 ex rel. | 2 | 1977–1991 |
Harrington v. California
red
2 sentences1971That it came voluntarily from Nathaniel instead of being wrung from him on cross-examination shows only that cross-examination was unnecessary and not that it was unavailable. * We hold, therefore, that John suffered no deprivation of his constitutional right of confrontation which made the admission of Nathaniel’s confession constitutionally invalid as to John.* [ 415 F. 2d at 571-573 ] However, even if Wade were not entirely controlling, we find that, in light of the record, any Bruton error was “harmless beyond a reasonable donbt.” Harrington v. California, 395 U. S. 250 , 89 S. Ct. 1726 , 1971That it came voluntarily from Nathaniel instead of being wrung from him on cross-examination shows only that cross-examination was unnecessary and not that it was unavailable. * We hold, therefore, that John suffered no deprivation of his constitutional right of confrontation which made the admission of Nathaniel’s confession constitutionally invalid as to John.* [ 415 F. 2d at 571-573 ] However, even if Wade were not entirely controlling, we find that, in light of the record, any Bruton error was “harmless beyond a reasonable donbt.” Harrington v. California, 395 U. S. 250 , 89 S. Ct. 1726 , | 2 | 1971–1971 |
Chapman v. California
red
2 sentences1971That it came voluntarily from Nathaniel instead of being wrung from him on cross-examination shows only that cross-examination was unnecessary and not that it was unavailable. [*] We hold, therefore, that John suffered no deprivation of his constitutional right of confrontation which made the admission of Nathaniel's confession constitutionally invalid as to John. [*] [ 415 F. 2d at 571-573 ] However, even if Wade were not entirely controlling, we find that, in light of the record, any Bruton error was "harmless beyond a reasonable doubt." Harrington v. California, 395 U.S. 250 , 89 S.Ct. 1726 1971That it came voluntarily from Nathaniel instead of being wrung from him on cross-examination shows only that cross-examination was unnecessary and not that it was unavailable. [*] We hold, therefore, that John suffered no deprivation of his constitutional right of confrontation which made the admission of Nathaniel's confession constitutionally invalid as to John. [*] [ 415 F. 2d at 571-573 ] However, even if Wade were not entirely controlling, we find that, in light of the record, any Bruton error was "harmless beyond a reasonable doubt." Harrington v. California, 395 U.S. 250 , 89 S.Ct. 1726 | 2 | 1971–1971 |
John D. Wade v. Howard Yeager, Warden, New Jersey State Prison, and State of New Jersey
green
2 sentences1971That it came voluntarily from Nathaniel instead of being wrung from him on cross-examination shows only that cross-examination was unnecessary and not that it was unavailable. * We hold, therefore, that John suffered no deprivation of his constitutional right of confrontation which made the admission of Nathaniel’s confession constitutionally invalid as to John.* [ 415 F. 2d at 571-573 ] However, even if Wade were not entirely controlling, we find that, in light of the record, any Bruton error was “harmless beyond a reasonable donbt.” Harrington v. California, 395 U. S. 250 , 89 S. Ct. 1726 , 1971That it came voluntarily from Nathaniel instead of being wrung from him on cross-examination shows only that cross-examination was unnecessary and not that it was unavailable. [*] We hold, therefore, that John suffered no deprivation of his constitutional right of confrontation which made the admission of Nathaniel's confession constitutionally invalid as to John. [*] [ 415 F. 2d at 571-573 ] However, even if Wade were not entirely controlling, we find that, in light of the record, any Bruton error was "harmless beyond a reasonable doubt." Harrington v. California, 395 U.S. 250 , 89 S.Ct. 1726 | 2 | 1971–1971 |
Homer E. Hanrahan v. James Greer, Warden, Menard Correctional Center
green
1 sentence1991Hanrahan v. Greer, 896 F.2d 241 (7th Cir.1990). | 1 | 1991–1991 |
State v. Barrett
green
2 sentences1990While recognizing that Bruton required severance of trials before admissibility of an extra-judicial declaration of a codefendant which included inculpatory references to defendant, the judge distinguished the Bruton rule from the issue at hand because "an out-of-court confession by a defendant implicating a codefendant is inadmissible under Bruton because by its nature, it is unverifiable hearsay." Barrett, supra, 220 N.J. 1990Super. at 315 , 531 A. 2d 1368 (footnotes omitted). | 1 | 1990–1990 |
Yacker v. Advisory Committee On Professional Ethics
neutral
2 sentences1985As Judge Dreier observed in State v. Haskell, 195 N.J.Super. 235, 237 (App.Div.), certif. granted 99 N.J. 198 (1984) (argued March 18, 1985), New Jersey’s appellate courts have never condoned or adopted the so-called “interlocking confessions” exception of Parker v. Randolph as a matter of State constitutional or procedural law. 1985As Judge Dreier observed in State v. Haskell, 195 N.J.Super. 235, 237 (App.Div.), certif. granted 99 N.J. 198 (1984) (argued March 18, 1985), New Jersey’s appellate courts have never condoned or adopted the so-called “interlocking confessions” exception of Parker v. Randolph as a matter of State constitutional or procedural law. | 1 | 1985–1985 |
Thomas v. Hempstead Union Free School District
neutral
2 sentences1985Cf. People v. Cardona, 56 A.D.2d 759 , 392 N.Y.S.2d 40 (App.Div. 1977) for an example of misuse of a co-defendant’s confession by the trial judge which resulted in a reversal. 1985Cf. People v. Cardona, 56 A.D.2d 759 , 392 N.Y.S.2d 40 (App.Div. 1977) for an example of misuse of a co-defendant’s confession by the trial judge which resulted in a reversal. | 1 | 1985–1985 |
People v. Cardona
neutral
2 sentences1985Cf. People v. Cardona, 56 A.D.2d 759 , 392 N.Y.S.2d 40 (App.Div. 1977) for an example of misuse of a co-defendant’s confession by the trial judge which resulted in a reversal. 1985Cf. People v. Cardona, 56 A.D.2d 759 , 392 N.Y.S.2d 40 (App.Div. 1977) for an example of misuse of a co-defendant’s confession by the trial judge which resulted in a reversal. | 1 | 1985–1985 |
Berger v. New York
green
1 sentence1971That it came voluntarily from Nathaniel instead of being wrung from him on cross-examination shows only that cross-examination was unnecessary and not that it was unavailable. [*] We hold, therefore, that John suffered no deprivation of his constitutional right of confrontation which made the admission of Nathaniel's confession constitutionally invalid as to John. [*] [ 415 F. 2d at 571-573 ] However, even if Wade were not entirely controlling, we find that, in light of the record, any Bruton error was "harmless beyond a reasonable doubt." Harrington v. California, 395 U.S. 250 , 89 S.Ct. 1726 | 1 | 1971–1971 |
Seymour v. United States
green
1 sentence1971That it came voluntarily from Nathaniel instead of being wrung from him on cross-examination shows only that cross-examination was unnecessary and not that it was unavailable. [*] We hold, therefore, that John suffered no deprivation of his constitutional right of confrontation which made the admission of Nathaniel's confession constitutionally invalid as to John. [*] [ 415 F. 2d at 571-573 ] However, even if Wade were not entirely controlling, we find that, in light of the record, any Bruton error was "harmless beyond a reasonable doubt." Harrington v. California, 395 U.S. 250 , 89 S.Ct. 1726 | 1 | 1971–1971 |
Dutton v. Evans
green
2 sentences1971That it came voluntarily from Nathaniel instead of being wrung from him on cross-examination shows only that cross-examination was unnecessary and not that it was unavailable. [*] We hold, therefore, that John suffered no deprivation of his constitutional right of confrontation which made the admission of Nathaniel's confession constitutionally invalid as to John. [*] [ 415 F. 2d at 571-573 ] However, even if Wade were not entirely controlling, we find that, in light of the record, any Bruton error was "harmless beyond a reasonable doubt." Harrington v. California, 395 U.S. 250 , 89 S.Ct. 1726 1971That it came voluntarily from Nathaniel instead of being wrung from him on cross-examination shows only that cross-examination was unnecessary and not that it was unavailable. [*] We hold, therefore, that John suffered no deprivation of his constitutional right of confrontation which made the admission of Nathaniel's confession constitutionally invalid as to John. [*] [ 415 F. 2d at 571-573 ] However, even if Wade were not entirely controlling, we find that, in light of the record, any Bruton error was "harmless beyond a reasonable doubt." Harrington v. California, 395 U.S. 250 , 89 S.Ct. 1726 | 1 | 1971–1971 |
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.