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Bruton v. United States

Facts of the Case

Provided by Oyez

George William Bruton and William James Evans were tried together for robbing a jewelry store that also operated as a U.S. Postal Service contract station. At trial, the judge admitted in to evidence Evans’ confessions, made to the postal inspector and later to police. In the confession, Evans names Bruton as his accomplice. The judge instructed the jury to consider the confession for Evans’ guilt or innocence, but to disregard it as inadmissible hearsay for Bruton’s charges. The jury convicted both men. Evans and Bruton appealed to the U.S. Court of Appeals for the Eighth Circuit. That court set aside Evans’ conviction, finding that the confession to the postal inspector should not have been received into evidence. The court upheld Bruton’s conviction because the district court properly instructed the jury not to use the confession when considering Bruton’s charges.

Questions

  1. Was George Bruton substantially prejudiced against when the jury heard an improperly obtained admission by a co-defendant, which implicated Bruton in the crime?

Conclusions

  1. Yes. Justice William J. Brennan, Jr., writing for a 6-2 majority, reversed the lower court. The Supreme Court held that Bruton was substantially prejudiced against because of the high risk that the jury considered Evans’ confession when deciding Bruton’s guilt. Admitting Evans’ confession into evidence violated Bruton’s Sixth Amendment right to cross-examination. This decision expressly overruled Delli Paoli v. United States. Justice Potter Stewart concurred, expressing that certain kinds of hearsay are so damaging that jurors cannot be trusted to give that evidence the minimal weight it deserves. Justice Hugo L. Black also concurred, writing that a jury instruction to use a confession as evidence against one defendant but not the other in the same trial is ineffective.

    Justice Byron R. White dissented, stating that juries can be reasonably relied upon to follow jury instructions and disregard certain evidence. Justice John M. Harlan joined in the dissent. Justice Thurgood Marshall did not participate.