Help us improve in just 2 minutes—share your thoughts in our reader survey.

Samia v. United States

From Ballotpedia
Jump to: navigation, search

Supreme Court of the United States
Samia v. United States
Term: 2022
Important Dates
Argued: March 29, 2023
Decided: June 23, 2023
Outcome
affirmed
Vote
6-3
Majority
Clarence Thomas • Chief Justice John Roberts • Samuel Alito • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett (in part)
Concurring
Amy Coney Barrett
Dissenting
Elena Kagan • Sonia Sotomayor • Ketanji Brown Jackson

Samia v. United States is a case that was decided by the Supreme Court of the United States on June 23, 2023, during the court's October 2022-2023 term. The case was argued before the court on March 29, 2023. The court affirmed the decision of the United States Court of Appeals for the 2nd Circuit in a 6-3 ruling, holding that "[t]he Confrontation Clause was not violated by the admission of a nontestifying codefendant’s confession that did not directly inculpate the defendant and was subject to a proper limiting instruction."[1] Justice Clarence Thomas delivered the majority opinion of the court. Justice Elena Kagan filed a dissenting opinion, joined by Justice Sonia Sotomayor. Justice Ketanji Brown Jackson also filed a dissenting opinion.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned the right of a defendant to confront the witnesses against them, known as the Confrontation Clause of the U.S. Constitution's Sixth Amendment. Click here to learn more about the case's background.
  • The questions presented: "Whether admitting a codefendant’s redacted out-of-court confession that immediately inculpates a defendant based on the surrounding context violates the defendant’s rights under the Confrontation Clause of the Sixth Amendment."[2]
  • The outcome: In a 6-3 ruling, the court affirmed the decision of the United States Court of Appeals for the 2nd Circuit.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 2nd Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    Adam Samia was convicted and sentenced to life in prison for participating in the murder of Philippines real estate agent Catherine Lee. The U.S. government alleged that Samia was one of the murderers, identifying him in part through oral testimony—the confession of co-conspirator David Stillwell (also known as Bill Maxwell) at trial. Prosecutors redacted Stillwell’s confession to remove Samia's name and the judge instructed the jury to consider the confession in weighing Stillwell's guilt only. Samia argued that he was never conclusively identified as one of the co-conspirators, as none of the evidence was related exclusively to him. He concluded that the evidence against him didn't meet the standard required by United States v. Lyle (2019). Nevertheless, the jury convicted all three co-conspirators (Samia, Stillwell, and Joseph Hunter) on all counts.[2][3][4]

    On April 20, 2022, the United States Court of Appeals for the 2nd Circuit affirmed in part and vacated in part the district court's judgment and remanded the case for further proceedings. The court held:[3]

    “ ... In Bruton v. United States, 391 U.S 123 (1968), the Supreme Court held that in joint trials, the admission of a non-testifying defendant's confession incriminating a co-defendant without the opportunity for cross-examination is prejudicial error in violation of the Sixth Amendment's Confrontation Clause.


    ... Samia contends that the redactions to Stillwell's confession were insufficient because jurors would immediately infer that Stillwell's references to "another person" referred to Samia himself.

    The argument is defeated by precedent. "We have consistently held that the introduction of a co-defendant's confession with the defendant's name replaced by a neutral noun or pronoun does not violate Bruton." Id. at 733. The Drug Enforcement Agency agent here, through whom the redacted confession was introduced, used such neutral terms, recounting Stillwell's confession that he was with "somebody else over there" and that he lived with "the other person." J.A. 516. The agent also recounted Stillwell's description of a "time when the other person he was with pulled the trigger on that woman in a van that he and Mr. Stillwell was driving." Id. Viewed "separate and apart from any other evidence," Lyle, 919 F.3d at 733, these statements do not "explicit[ly] identif[y]" Samia, Jass, 569 F.3d at 61. Nor is the use of neutral language to replace explicit identification so awkward or obvious as to tip off the jury that a redaction has occurred. Rather, a juror listening to these statements could have concluded that several other people may have been Stillwell's co-conspirator.

    Samia also contends that the District Court erred by permitting the Government to ask- and the Agent to answer-questions about "the other person." By soliciting such information about the "other person," Samia contends, the Government directly counteracted the effectiveness of the neutrally worded redaction.

    The record does not support that argument. The challenged questioning elicited testimony that the person Stillwell was with carried a firearm with a silencer. That additional information, considered by itself and separate from other evidence, did not make it more likely that Stillwell's confession implicated Samia.

    Accordingly, there was no error in admitting Stillwell's confession in its modified form.

    ... For the foregoing reasons, we AFFIRM the District Court's judgments and order with respect to Count Three for Hunter and Counts Three and Five for both Samia and Stillwell. However, by agreement of the Government, we VACATE the convictions of Defendants with respect to Counts One, Two, and Four and we REMAND the cause to the District Court for resentencing upon consideration of this decision.[5]

    		”

    On August 30, 2022, Samia appealed to the U.S. Supreme Court, asking the court to consider whether the admittance of Stillwell's confession was constitutional under the Confrontation Clause of the Sixth Amendment. SCOTUS accepted the case to its merits docket to be argued during its October term 2022-2023 on December 13, 2022.[2][3]

    Sixth Amendment

    The text of Amendment VI is as follows:

    Text of Amendment VI:

    In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed, which district shall have been previously ascertained by law, and to be informed of the nature and cause of the accusation; to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor, and to have the Assistance of Counsel for his defence.

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether admitting a codefendant’s redacted out-of-court confession that immediately inculpates a defendant based on the surrounding context violates the defendant’s rights under the Confrontation Clause of the Sixth Amendment.[5] ”

    Oral argument

    Audio

    Audio of oral argument:[6]




    Transcript

    Transcript of oral argument:[7]

    Outcome

    In a 6-3 opinion, the court affirmed the judgment of the United States Court of Appeals for the 2nd Circuit, holding that "[t]he Confrontation Clause was not violated by the admission of a nontestifying codefendant’s confession that did not directly inculpate the defendant and was subject to a proper limiting instruction."[1] Justice Clarence Thomas delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Clarence Thomas wrote:[1]

    “

    Prosecutors have long tried criminal defendants jointly in cases where the defendants are alleged to have engaged in a common criminal scheme. However, when prosecutors seek to introduce a nontestifying defendant’s confession implicating his codefendants, a constitutional concern may arise. The Confrontation Clause of the Sixth Amendment states that, “[i]n all criminal prosecutions, the accused shall enjoy the right . . . to be confronted with the witnesses against him.” And, in Bruton v. United States, 391 U. S. 123 (1968), this Court “held that a defendant is deprived of his rights under the Confrontation Clause when his nontestifying codefendant’s confession naming him as a participant in the crime is introduced at their joint trial, even if the jury is instructed to consider that confession only against the codefendant.” Richardson v. Marsh, 481 U. S. 200, 201–202 (1987).

    Here, we must determine whether the Confrontation Clause bars the admission of a nontestifying codefendant’s confession where (1) the confession has been modified to avoid directly identifying the nonconfessing codefendant and (2) the court offers a limiting instruction that jurors may consider the confession only with respect to the confessing codefendant. Considering longstanding historical practice, the general presumption that jurors follow their instructions, and the relevant precedents of this Court, we conclude that it does not. [5]

    		”
    —Justice Clarence Thomas

    Concurring opinion

    Justice Amy Coney Barrett filed a concurring opinion.

    In her concurring opinion, Justice Barrett wrote:[1]

    “

    I agree that the admission of Stillwell’s modified confession, together with a limiting instruction, did not violate the Confrontation Clause. But in my view, the historical evidence described in Part II–A, ante, is beside the point... At best, the evidence recounted in Part II–A shows that, during a narrow historical period, some courts assumed and others expressly held that a limiting instruction sufficiently protected a codefendant from a declaration inadmissible on hearsay grounds. In suggesting anything more, the Court overclaims. That is unfortunate. While history is often important and sometimes dispositive, we should be discriminating in its use. Otherwise, we risk undermining the force of historical arguments when they matter most. [5]

    		”
    —Justice Amy Coney Barrett

    Kagan's dissenting opinion

    Justice Elena Kagan filed a dissenting opinion, joined by Justice Sonia Sotomayor.

    In her dissent, Justice Kagan wrote:[1]

    “

    Imagine a criminal case involving two defendants—John and Mary. John and Mary are arrested for robbing Bill. Before trial, John confesses to the robbery in an interview with police. But John does more than admit his own involvement; he also points a finger at Mary. John says to the police: “Mary and I went out Saturday night and robbed Bill.” Mary, on the other hand, never confesses to the robbery. She maintains that she wasn’t involved—in fact, that she never left her home on the night in question. The government tries John and Mary together. At trial, it introduces a copy of John’s confession into evidence, and has it read to the jury by the interviewing officer. But John elects not to take the stand, leaving Mary’s attorney without an opportunity to cross-examine him about his confession.

    This Court’s precedent bars the government from using John’s confession in that way. [5]

    		”
    —Justice Elena Kagan

    Jackson's dissenting opinion

    Justice Ketanji Brown Jackson also filed a dissenting opinion.

    In her dissent, Justice Jackson wrote:[1]

    “

    I join JUSTICE KAGAN’s dissent in full, and agree, in particular, with her insight that the majority’s bottom-line view is that “Bruton should go.” Ante, at 10. I am writing to emphasize that most of the force of the Court’s argument (to the extent that it is at all forceful) comes from the majority having improperly reframed the constitutional standard that applies to the admission of incriminating testimonial statements of a codefendant during a joint criminal trial. [5]

    		”
    —Justice Ketanji Brown Jackson

    Text of the opinion

    Read the full opinion here.

    October term 2022-2023

    See also: Supreme Court cases, October term 2022-2023

    The Supreme Court began hearing cases for the term on October 3, 2022. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[8]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 SUPREME COURT OF THE UNITED STATES , "SAMIA, AKA SAMIC v. UNITED STATES," decided June 23, 2023
    2. ↑ 2.0 2.1 2.2 2.3 U.S. Supreme Court, "Samia v. United States ON PETITION FOR A WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT," filed August 30, 2022
    3. ↑ 3.0 3.1 3.2 3.3 U.S. Court of Appeals for the 2nd Circuit, United States v. Hunter, decided April 20, 2022
    4. ↑ SCOTUSblog, "Justices grant review in two criminal cases and a securities lawsuit against Slack," December 13, 2022
    5. ↑ 5.0 5.1 5.2 5.3 5.4 5.5 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued March 29,2023
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued March 29,2023
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
    Retrieved from "https://ballotpedia.org/wiki/index.php?title=Samia_v._United_States&oldid=9164404"