Gray v. Maryland
United States Supreme Court
523 U.S. 185 (1998)
Bell confessed to police that he and Gray (defendant) had jointly beaten a man to death; at their joint trial, Bell's confession was admitted with Gray's name replaced by the word "deleted" when read aloud, and by a blank space set off by commas in the written version, with the judge instructing the jury the confession was evidence only against Bell. Immediately after reading the redacted confession, the prosecutor asked the testifying officer whether the information from Bell let him then arrest Gray, and the officer said yes. The jury convicted both men; Maryland's intermediate court reversed Gray's conviction under Bruton v. United States, but Maryland's highest court reinstated it, reasoning the redaction (following Richardson v. Marsh) cured any Confrontation Clause problem.
Whether out-of-court statements by a codefendant that incriminate another defendant are inadmissible at trial, even with a limiting instruction or with the incriminated defendant's name redacted.