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7 South Carolina opinions name it 2 courts 1976–2017 0 in the last five years
The cases below were cited by South Carolina 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 |
|---|---|---|
Schneble v. Floridagreen2 sentences2017In McDonald and State v. Henson , 407 S.C. 154 , 167, 754 S.E.2d 508 , 515 (2014), our supreme court quoted Schneble v. Florida , 405 U.S. 427 , 430, 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972) : "In some cases the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the codefendant'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." Whether a Bruton error is harmless depends upon numerous factors including "the importance of the witness's testimony in *898 the prosecuti 2017In McDonald and State v. Henson , 407 S.C. 154 , 167, 754 S.E.2d 508 , 515 (2014), our supreme court quoted Schneble v. Florida , 405 U.S. 427 , 430, 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972) : "In some cases the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the codefendant'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." Whether a Bruton error is harmless depends upon numerous factors including "the importance of the witness's testimony in *898 the prosecuti | 3 | 4 |
State v. Hensongreen2 sentences2017In McDonald and State v. Henson , 407 S.C. 154 , 167, 754 S.E.2d 508 , 515 (2014), our supreme court quoted Schneble v. Florida , 405 U.S. 427 , 430, 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972) : "In some cases the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the codefendant'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." Whether a Bruton error is harmless depends upon numerous factors including "the importance of the witness's testimony in *898 the prosecuti 2017In McDonald and State v. Henson , 407 S.C. 154 , 167, 754 S.E.2d 508 , 515 (2014), our supreme court quoted Schneble v. Florida , 405 U.S. 427 , 430, 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972) : "In some cases the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the codefendant'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." Whether a Bruton error is harmless depends upon numerous factors including "the importance of the witness's testimony in *898 the prosecuti | 2 | 2 |
State v. McDonaldgreen2 sentences2017See Schneble , 405 U.S. at 431 , 92 S.Ct. 1056 (finding a Bruton violation to be harmless error when the "details of petitioner's [confession] were internally consistent, were corroborated by other objective evidence, and were not contradicted by any other evidence in the case"); accord McDonald , 412 S.C. at 143 -44 , 771 S.E.2d at 845 . 2017See Schneble , 405 U.S. at 431 , 92 S.Ct. 1056 (finding a Bruton violation to be harmless error when the "details of petitioner's [confession] were internally consistent, were corroborated by other objective evidence, and were not contradicted by any other evidence in the case"); accord McDonald , 412 S.C. at 143 -44 , 771 S.E.2d at 845 . | 1 | 1 |
United States v. Schwartzgreen2 sentences2014See also United States v. Schwartz, 541 F.3d 1331, 1351-52 (11th Cir.2008) (finding a Bruton violation “[ejven though [the codefendant]’s statement ‘was not incriminating on its face, and became so only when linked’ with other evidence” because the statement named the defendant’s “corporations after the jury had heard lengthy testimony regarding the extent of [the defendant’s ownership and control of them” (quoting Richardson, 481 U.S. at 208 , 107 S.Ct. at 1707 , 95 L.Ed.2d at 186 )); United States v. Mayfield, 189 F.3d 895, 902 (9th Cir.1999) (finding a Bruton violation because “the impermis 2014See also United States v. Schwartz, 541 F.3d 1331, 1351-52 (11th Cir.2008) (finding a Bruton violation “[ejven though [the codefendant]’s statement ‘was not incriminating on its face, and became so only when linked’ with other evidence” because the statement named the defendant’s “corporations after the jury had heard lengthy testimony regarding the extent of [the defendant’s ownership and control of them” (quoting Richardson, 481 U.S. at 208 , 107 S.Ct. at 1707 , 95 L.Ed.2d at 186 )); United States v. Mayfield, 189 F.3d 895, 902 (9th Cir.1999) (finding a Bruton violation because “the impermis | 1 | 1 |
United States v. Greengreen1 sentence2014See, e.g., United States v. Green, 648 F.3d 569, 575 (7th Cir.2011) (citing this passage from Gray as the standard courts apply “when the defendant’s identity can be established through other evidence” and finding no Bruton violation); In re Terrorist Bombings of U.S. Embassies in E. | 1 | 1 |
Gray v. Marylandgreen2 sentences2014In Gray , the Supreme Court defined the kind of inference required for a Bruton violation, holding the admission of a codefendant’s statement violates Bruton when the “statements ..., despite redaction, obviously refer directly to someone, often obviously the defendant, and which involve inferences that a jury ordi narily could make immediately.” 523 U.S. at 196 , 118 S.Ct. at 1157 , 140 L.Ed.2d at 303 . 2014In Gray , the Supreme Court defined the kind of inference required for a Bruton violation, holding the admission of a codefendant’s statement violates Bruton when the “statements ..., despite redaction, obviously refer directly to someone, often obviously the defendant, and which involve inferences that a jury ordi narily could make immediately.” 523 U.S. at 196 , 118 S.Ct. at 1157 , 140 L.Ed.2d at 303 . | 1 | 1 |
Edmond v. Stategreen2 sentences2014See also 407 S.C. at 158, 167 , 754 S.E.2d at 510, 515 (finding a Bruton violation and concluding the error was not harmless, even where two coconspirators testified Henson was the shooter and gave other testimony corroborating the State’s evidence against him); State v. Singleton, 303 S.C. 313, 314-15 , 400 S.E.2d 487, 487-88 (1991) (finding a Bruton violation and concluding the error was not harmless, even where “[t]he victim testified that appellant walked up to his car, pointed a pistol in the car and demanded he turn over his money”); Edmond v. State, 341 S.C. 340, 349 , 534 S.E.2d 682, 6 2014See also 407 S.C. at 158, 167 , 754 S.E.2d at 510, 515 (finding a Bruton violation and concluding the error was not harmless, even where two coconspirators testified Henson was the shooter and gave other testimony corroborating the State’s evidence against him); State v. Singleton, 303 S.C. 313, 314-15 , 400 S.E.2d 487, 487-88 (1991) (finding a Bruton violation and concluding the error was not harmless, even where “[t]he victim testified that appellant walked up to his car, pointed a pistol in the car and demanded he turn over his money”); Edmond v. State, 341 S.C. 340, 349 , 534 S.E.2d 682, 6 | 1 | 1 |
State v. Sheppardgreen2 sentences2014See State v. Sheppard, 391 S.C. 415, 421 , 706 S.E.2d 16, 19 (2011) (stating “the plain error rule does not apply in South Carolina state courts”); State v. Evans, 316 S.C. 303 , 307 n. 1, 450 S.E.2d 47 , 50 n. 1 (1994) (finding that when a defendant claiming a Bruton violation “did not request [a limiting instruction] nor make the argument [on appeal] that the failure to give a limiting instruction was error ..., [the argument] has been waived”). 2014See State v. Sheppard, 391 S.C. 415, 421 , 706 S.E.2d 16, 19 (2011) (stating “the plain error rule does not apply in South Carolina state courts”); State v. Evans, 316 S.C. 303 , 307 n. 1, 450 S.E.2d 47 , 50 n. 1 (1994) (finding that when a defendant claiming a Bruton violation “did not request [a limiting instruction] nor make the argument [on appeal] that the failure to give a limiting instruction was error ..., [the argument] has been waived”). | 1 | 1 |
State v. Johnsongreen2 sentences2014In State v. Johnson, 390 S.C. 600 , 703 S.E.2d 217 (2010), our supreme court relied on an investigator’s testimony that the defendant’s arrest was based in part on the codefendant’s statement in finding a Bruton violation. 390 S.C. at 605 , 703 S.E.2d at 219 . 2014In State v. Johnson, 390 S.C. 600 , 703 S.E.2d 217 (2010), our supreme court relied on an investigator’s testimony that the defendant’s arrest was based in part on the codefendant’s statement in finding a Bruton violation. 390 S.C. at 605 , 703 S.E.2d at 219 . | 1 | 1 |
United States v. Jerry Wayne Mayfieldgreen2 sentences2014See also United States v. Schwartz, 541 F.3d 1331, 1351-52 (11th Cir.2008) (finding a Bruton violation “[ejven though [the codefendant]’s statement ‘was not incriminating on its face, and became so only when linked’ with other evidence” because the statement named the defendant’s “corporations after the jury had heard lengthy testimony regarding the extent of [the defendant’s ownership and control of them” (quoting Richardson, 481 U.S. at 208 , 107 S.Ct. at 1707 , 95 L.Ed.2d at 186 )); United States v. Mayfield, 189 F.3d 895, 902 (9th Cir.1999) (finding a Bruton violation because “the impermis 2014See also United States v. Schwartz, 541 F.3d 1331, 1351-52 (11th Cir.2008) (finding a Bruton violation “[ejven though [the codefendant]’s statement ‘was not incriminating on its face, and became so only when linked’ with other evidence” because the statement named the defendant’s “corporations after the jury had heard lengthy testimony regarding the extent of [the defendant’s ownership and control of them” (quoting Richardson, 481 U.S. at 208 , 107 S.Ct. at 1707 , 95 L.Ed.2d at 186 )); United States v. Mayfield, 189 F.3d 895, 902 (9th Cir.1999) (finding a Bruton violation because “the impermis | 1 | 1 |
State v. Singletongreen2 sentences2014See also 407 S.C. at 158, 167 , 754 S.E.2d at 510, 515 (finding a Bruton violation and concluding the error was not harmless, even where two coconspirators testified Henson was the shooter and gave other testimony corroborating the State’s evidence against him); State v. Singleton, 303 S.C. 313, 314-15 , 400 S.E.2d 487, 487-88 (1991) (finding a Bruton violation and concluding the error was not harmless, even where “[t]he victim testified that appellant walked up to his car, pointed a pistol in the car and demanded he turn over his money”); Edmond v. State, 341 S.C. 340, 349 , 534 S.E.2d 682, 6 2014See also 407 S.C. at 158, 167 , 754 S.E.2d at 510, 515 (finding a Bruton violation and concluding the error was not harmless, even where two coconspirators testified Henson was the shooter and gave other testimony corroborating the State’s evidence against him); State v. Singleton, 303 S.C. 313, 314-15 , 400 S.E.2d 487, 487-88 (1991) (finding a Bruton violation and concluding the error was not harmless, even where “[t]he victim testified that appellant walked up to his car, pointed a pistol in the car and demanded he turn over his money”); Edmond v. State, 341 S.C. 340, 349 , 534 S.E.2d 682, 6 | 1 | 1 |
Barry Priester v. Donald T. Vaughn the District Attorney of the County of Philadelphia the Attorney General of the State of Pennsylvaniagreen2 sentences2014In Priester v. Vaughn, 382 F.3d 394 (3d Cir.2004), the appellant sought habeas corpus relief for an alleged Bruton violation in his 1991 trial for murder. 382 F.3d at 395-96, 397 . 9 The Third Circuit found no Bruton violation because the statements contained “no ... ‘nicknames,’ descriptions or phrases that directly implicate[d]” the appellant, and the phrases used for redaction were “bereft of any innuendo that ties them unavoidably to” him. 382 F.3d at 400-01 . 2014In Priester v. Vaughn, 382 F.3d 394 (3d Cir.2004), the appellant sought habeas corpus relief for an alleged Bruton violation in his 1991 trial for murder. 382 F.3d at 395-96, 397 . 9 The Third Circuit found no Bruton violation because the statements contained “no ... ‘nicknames,’ descriptions or phrases that directly implicate[d]” the appellant, and the phrases used for redaction were “bereft of any innuendo that ties them unavoidably to” him. 382 F.3d at 400-01 . | 1 | 1 |
Richardson v. Marshgreen2 sentences2014See also United States v. Schwartz, 541 F.3d 1331, 1351-52 (11th Cir.2008) (finding a Bruton violation “[ejven though [the codefendant]’s statement ‘was not incriminating on its face, and became so only when linked’ with other evidence” because the statement named the defendant’s “corporations after the jury had heard lengthy testimony regarding the extent of [the defendant’s ownership and control of them” (quoting Richardson, 481 U.S. at 208 , 107 S.Ct. at 1707 , 95 L.Ed.2d at 186 )); United States v. Mayfield, 189 F.3d 895, 902 (9th Cir.1999) (finding a Bruton violation because “the impermis 2014See also United States v. Schwartz, 541 F.3d 1331, 1351-52 (11th Cir.2008) (finding a Bruton violation “[ejven though [the codefendant]’s statement ‘was not incriminating on its face, and became so only when linked’ with other evidence” because the statement named the defendant’s “corporations after the jury had heard lengthy testimony regarding the extent of [the defendant’s ownership and control of them” (quoting Richardson, 481 U.S. at 208 , 107 S.Ct. at 1707 , 95 L.Ed.2d at 186 )); United States v. Mayfield, 189 F.3d 895, 902 (9th Cir.1999) (finding a Bruton violation because “the impermis | 1 | 1 |
State v. Vincentgreen2 sentences2014State v. Holder, 382 S.C. 278 , 285 n. 3, 676 S.E.2d 690 , 694 n. 3 (2009); see id. (explaining “the use of ‘the other guy’ ha[s] been upheld as a proper substitution in previous cases,” but “there could be some instances where this identical phrase would not be [a] sufficient” redaction (citing State v. Vincent, 131 Wash. App. 147 , 120 P.3d 120, 123-24 (2005))). 2014State v. Holder, 382 S.C. 278 , 285 n. 3, 676 S.E.2d 690 , 694 n. 3 (2009); see id. (explaining “the use of ‘the other guy’ ha[s] been upheld as a proper substitution in previous cases,” but “there could be some instances where this identical phrase would not be [a] sufficient” redaction (citing State v. Vincent, 131 Wash. App. 147 , 120 P.3d 120, 123-24 (2005))). | 1 | 1 |
United States v. Odehgreen1 sentence2014Afr., 552 F.3d 93, 134 (2d Cir.2008) (noting “whether ... redaction sufficiently protects a criminal defendant’s rights ‘depend[s] in significant part upon the kind of ... inference’ that the jury may draw,” and citing the passage from Gray as the standard for determining whether statements “have the effect of ‘facially incriminating] the ... co-defendant,’ thereby rendering them unsuitable for admission under Bruton” (alteration in original) (quoting Gray, 523 U.S. at 196 , 118 S.Ct. at 1157 , 140 L.Ed.2d at 303 )). | 1 | 1 |
In Re Mayergreen2 sentences2014State v. Holder, 382 S.C. 278 , 285 n. 3, 676 S.E.2d 690 , 694 n. 3 (2009); see id. (explaining “the use of ‘the other guy’ ha[s] been upheld as a proper substitution in previous cases,” but “there could be some instances where this identical phrase would not be [a] sufficient” redaction (citing State v. Vincent, 131 Wash. App. 147 , 120 P.3d 120, 123-24 (2005))). 2014State v. Holder, 382 S.C. 278 , 285 n. 3, 676 S.E.2d 690 , 694 n. 3 (2009); see id. (explaining “the use of ‘the other guy’ ha[s] been upheld as a proper substitution in previous cases,” but “there could be some instances where this identical phrase would not be [a] sufficient” redaction (citing State v. Vincent, 131 Wash. App. 147 , 120 P.3d 120, 123-24 (2005))). | 1 | 1 |
State v. Jahnell Weaver (069185)green2 sentences2014See also United States v. Schwartz, 541 F.3d 1331, 1351-52 (11th Cir.2008) (finding a Bruton violation “[ejven though [the codefendant]’s statement ‘was not incriminating on its face, and became so only when linked’ with other evidence” because the statement named the defendant’s “corporations after the jury had heard lengthy testimony regarding the extent of [the defendant’s ownership and control of them” (quoting Richardson, 481 U.S. at 208 , 107 S.Ct. at 1707 , 95 L.Ed.2d at 186 )); United States v. Mayfield, 189 F.3d 895, 902 (9th Cir.1999) (finding a Bruton violation because “the impermis 2014See also United States v. Schwartz, 541 F.3d 1331, 1351-52 (11th Cir.2008) (finding a Bruton violation “[ejven though [the codefendant]’s statement ‘was not incriminating on its face, and became so only when linked’ with other evidence” because the statement named the defendant’s “corporations after the jury had heard lengthy testimony regarding the extent of [the defendant’s ownership and control of them” (quoting Richardson, 481 U.S. at 208 , 107 S.Ct. at 1707 , 95 L.Ed.2d at 186 )); United States v. Mayfield, 189 F.3d 895, 902 (9th Cir.1999) (finding a Bruton violation because “the impermis | 1 | 1 |
Cruz v. New Yorkgreen2 sentences2003In some cases 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.”); Cruz v. New York , 481 U.S. 186, 193-94 (1987) (“[W]here a nontestifying codefendant’s confession incriminating the defendant is not directly admissible against the defendant . . . the Confrontation Clause bars its admission at their joint trial. . . . 2003In some cases 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.”); Cruz v. New York , 481 U.S. 186, 193-94 (1987) (“[W]here a nontestifying codefendant’s confession incriminating the defendant is not directly admissible against the defendant . . . the Confrontation Clause bars its admission at their joint trial. . . . | 1 | 1 |
United States v. Jesus Vazquez, United States of America v. Esteban Pizarrogreen2 sentences1999Id. at 449-50 ; accord United States v. Vazquez, 857 F.2d 857, 864 (1st Cir.1988) (finding no Bruton violation in the admission of a customs official's testimony in a joint trial about a codefendant's excited utterance implicating defendant, which was made when authorities detained the two men). 1999Id. at 449-50 ; accord United States v. Vazquez, 857 F.2d 857, 864 (1st Cir.1988) (finding no Bruton violation in the admission of a customs official’s testimony in a joint trial about a codefendant’s excited utterance implicating defendant, which was made when authorities detained the two men). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in South Carolina. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Arizona v. Fulminante
green
2 sentences2017Although the decision dealt with a defendant's confession improperly admitted against him in his separate trial, Justice Kennedy's concurrence in Arizona v. Fulminante , 499 U.S. 279 , 313, 111 S.Ct. 1246 , 113 L.Ed.2d 302 (1991), emphasized that a court conducting a harmless-error inquiry must appreciate the indelible impact a full confession may have on the trier of fact.... 2017Although the decision dealt with a defendant's confession improperly admitted against him in his separate trial, Justice Kennedy's concurrence in Arizona v. Fulminante , 499 U.S. 279 , 313, 111 S.Ct. 1246 , 113 L.Ed.2d 302 (1991), emphasized that a court conducting a harmless-error inquiry must appreciate the indelible impact a full confession may have on the trier of fact.... | 1 | 2017–2017 |
State v. Tapp
green
2 sentences2017State v. Tapp , 398 S.C. 376 , 389, 728 S.E.2d 468 , 475 (2012). **626 While we have not based the error here on Bruton or other constitutional grounds, the analysis for ascertaining the harmfulness of a Bruton error remains useful, and is not functionally different from the test for trial errors outlined above. 2017State v. Tapp , 398 S.C. 376 , 389, 728 S.E.2d 468 , 475 (2012). **626 While we have not based the error here on Bruton or other constitutional grounds, the analysis for ascertaining the harmfulness of a Bruton error remains useful, and is not functionally different from the test for trial errors outlined above. | 1 | 2017–2017 |
State v. Jenkins
green
2 sentences2017In McDonald and State v. Henson , 407 S.C. 154 , 167, 754 S.E.2d 508 , 515 (2014), our supreme court quoted Schneble v. Florida , 405 U.S. 427 , 430, 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972) : "In some cases the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the codefendant'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." Whether a Bruton error is harmless depends upon numerous factors including "the importance of the witness's testimony in *898 the prosecuti 2017In McDonald and State v. Henson , 407 S.C. 154 , 167, 754 S.E.2d 508 , 515 (2014), our supreme court quoted Schneble v. Florida , 405 U.S. 427 , 430, 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972) : "In some cases the properly admitted evidence of guilt is so overwhelming, and the prejudicial effect of the codefendant'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." Whether a Bruton error is harmless depends upon numerous factors including "the importance of the witness's testimony in *898 the prosecuti | 1 | 2017–2017 |
United States v. Larry Hoover, Tirenzy Wilson, Gregory Shell, Jerry Strawhorn, Adrian Bradd, Darrell Branch, Andrew Howard, and William Edwards
green
2 sentences2014In United States v. Hoover, 246 F.3d 1054 (7th Cir.2001), the Seventh Circuit found the phrases “incarcerated leader” and “unincarcerated leader” in a codefendant’s redacted statement were “obvious standins” for Hoover and Shell, two gang members. 246 F.3d at 1059 . 2014In United States v. Hoover, 246 F.3d 1054 (7th Cir.2001), the Seventh Circuit found the phrases “incarcerated leader” and “unincarcerated leader” in a codefendant’s redacted statement were “obvious standins” for Hoover and Shell, two gang members. 246 F.3d at 1059 . | 1 | 2014–2014 |
United States v. Gayekpar
green
2 sentences2014In Gayekpar , the Eighth Circuit found that although the redaction was sufficient, a Bruton violation occurred because the district court failed to give a limiting instruction. 678 F.3d at 637 . 2014In Gayekpar , the Eighth Circuit found that although the redaction was sufficient, a Bruton violation occurred because the district court failed to give a limiting instruction. 678 F.3d at 637 . | 1 | 2014–2014 |
State v. Evans
green
2 sentences2014See State v. Sheppard, 391 S.C. 415, 421 , 706 S.E.2d 16, 19 (2011) (stating “the plain error rule does not apply in South Carolina state courts”); State v. Evans, 316 S.C. 303 , 307 n. 1, 450 S.E.2d 47 , 50 n. 1 (1994) (finding that when a defendant claiming a Bruton violation “did not request [a limiting instruction] nor make the argument [on appeal] that the failure to give a limiting instruction was error ..., [the argument] has been waived”). 2014See State v. Sheppard, 391 S.C. 415, 421 , 706 S.E.2d 16, 19 (2011) (stating “the plain error rule does not apply in South Carolina state courts”); State v. Evans, 316 S.C. 303 , 307 n. 1, 450 S.E.2d 47 , 50 n. 1 (1994) (finding that when a defendant claiming a Bruton violation “did not request [a limiting instruction] nor make the argument [on appeal] that the failure to give a limiting instruction was error ..., [the argument] has been waived”). | 1 | 2014–2014 |
State v. Holder
green
2 sentences2014State v. Holder, 382 S.C. 278 , 285 n. 3, 676 S.E.2d 690 , 694 n. 3 (2009); see id. (explaining “the use of ‘the other guy’ ha[s] been upheld as a proper substitution in previous cases,” but “there could be some instances where this identical phrase would not be [a] sufficient” redaction (citing State v. Vincent, 131 Wash. App. 147 , 120 P.3d 120, 123-24 (2005))). 2014State v. Holder, 382 S.C. 278 , 285 n. 3, 676 S.E.2d 690 , 694 n. 3 (2009); see id. (explaining “the use of ‘the other guy’ ha[s] been upheld as a proper substitution in previous cases,” but “there could be some instances where this identical phrase would not be [a] sufficient” redaction (citing State v. Vincent, 131 Wash. App. 147 , 120 P.3d 120, 123-24 (2005))). | 1 | 2014–2014 |
United States v. Akin Akinkoye, A/K/A A. Sam Akins, United States of America v. Nouyibatou Afolabi
green
2 sentences2010This evidence violated the hearsay rules as well as appellant's Sixth Amendment Confrontation Clause rights. *607 The State argues this is not truly a Bruton error, citing United States v. Akinkoye, 185 F.3d 192 (4th Cir.1999). 2010This evidence violated the hearsay rules as well as appellant's Sixth Amendment Confrontation Clause rights. *607 The State argues this is not truly a Bruton error, citing United States v. Akinkoye, 185 F.3d 192 (4th Cir.1999). | 1 | 2010–2010 |
Lilly v. Virginia
green
2 sentences1999Our holding is consistent with Lilly v. Virginia, 527 U.S. 116 , 119 S.Ct. 1887 , 144 L.Ed.2d 117 (1999), a recent case in which the Supreme Court considered the Bruton doctrine, the Confrontation Clause, and firmly rooted hearsay exceptions. 1999Our holding is consistent with Lilly v. Virginia, 527 U.S. 116 , 119 S.Ct. 1887 , 144 L.Ed.2d 117 (1999), a recent case in which the Supreme Court considered the Bruton doctrine, the Confrontation Clause, and firmly rooted hearsay exceptions. | 1 | 1999–1999 |
George P. McLaughlin v. Douglas Vinzant, Superintendent, Etc.
green
2 sentences1999Id. at 449-50 ; accord United States v. Vazquez, 857 F.2d 857, 864 (1st Cir.1988) (finding no Bruton violation in the admission of a customs official's testimony in a joint trial about a codefendant's excited utterance implicating defendant, which was made when authorities detained the two men). 1999Id. at 449-50 ; accord United States v. Vazquez, 857 F.2d 857, 864 (1st Cir.1988) (finding no Bruton violation in the admission of a customs official’s testimony in a joint trial about a codefendant’s excited utterance implicating defendant, which was made when authorities detained the two men). | 1 | 1999–1999 |
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.