521 So. 2d 1106 - Puiatti v. State’s Empirical Analysis
1988
Citation profile
2 federal appellate · 9 state decisions
How this case has been cited
Cited by 15 later decisions — most recently October 2013
2 federal appellate · 9 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Bruton v. United States · Parker v. Randolph · United States v. Yellow Cab Co. · Cruz v. New York · Ohio v. Fleet Aerospace Corp.
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“As we interpret Cruz , trial courts must recognize that a nontestifying codefendant’s confession in a joint trial violates the confrontation clause except in those limited circumstances where indicia of reliability can be established. Once such a confession is introduced, the reviewing court must determine whether indicia of reliability exist or whether the introduction of a codefendant’s confession meets the harmless error test. We fully recognize the Supreme Court’s warning about the potential damning effects of a codefendant’s confession on the incriminated defendant. However, we find that the facts in the instant case are clearly distinguishable from those in Cruz because Puiatti and Glock not only entered into separate interlocking confessions, but they also subsequently entered into a joint confession resolving all prior inconsistencies. Neither Cruz nor Parker concerned a true joint confession entered into by both defendants. The joint confession, as we explained in the majority opinion, is substantially consistent with the individual confessions of Glock and Puiatti. Further, the joint confession was so interlocking, we do not believe Bruton applies because reliability was clearly established, but, even if it was error, its use with Glock’s name was harmless. We find the introduction of the individual confession of Glock to be harmless error under the circumstances of this case, and it falls squarely within the harmless error situation noted by Justice Blackmun when h”
4 later decisions quote this exact passage · from the concurrencee.g. Puiatti v. McNeil · Glock v. Dugger
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.