Zafiro v. United States

Zafiro, Martinez, Garcia, and Soto (defendants) were suspected of drug distribution and were indicted and tried together under Federal Rule of Criminal Procedure 8(b). Each blamed the others and claimed to be innocent. All four moved to sever their trials under Rule 14, arguing their defenses were 'mutually antagonistic.' The district court denied the motion, the defendants were convicted, and the court of appeals affirmed. The Supreme Court granted review.

Whether defendants properly joined for trial are entitled to severance as a matter of law under Rule 14 simply because their defenses are mutually antagonistic.