United States v. Williams’s Empirical Analysis

Citation profile

21 federal appellate · 5 district · 8 state decisions

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 70 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[T]he appropriate analysis to be used when applying the Bruton rule requires that we view the redacted confession in isolation from the other evidence introduced at trial. If the confession, when so viewed, does not incriminate the defendant, then it may be admitted with a proper limiting instruction even though other evidence in the case indicates that the neutral pronoun is in fact a reference to the defendant.”

   10 later decisions quote this exact passage · from the majority
   e.g. United States v. Hayhow · United States v. Green

2. “In cases such as the one before us now, where redaction is achieved through replacement of the defendant's name with a neutral pronoun or "blank," the ease with which a jury will be able to fill in a blank will vary from case to case, depending upon the overall evidentiary context in which it is introduced to the jury. A rule of admissibility per se is simply not appropriate for the form of redaction used in the case at bar. We therefore return to the basic tenets of Bruton . Because codefendant statements are "inevitably suspect" because of the strong potential for blame shifting, Bruton, supra, 391 U.S. p. 136, 88 S.Ct. p. 1628, even redacted confessions like the one challenged here should be clothed with a presumption of unreliability. If a "substantial risk" exists that the jury, despite cautionary instructions, will consider a codefendant's out-of-court statement in deciding the defendant's guilt, the statement — even though redacted to delete the defendant's name — will be rendered inadmissible at a joint trial. Bruton, supra, p. 128 , 88 S.Ct. p. 1622. Other independent evidence may, by necessity, have to be considered: "[T]he court must decide whether the statement incriminates the defendant against whom it is inadmissible in such a way as to create a `substantial risk' that the jury will look to the statement in deciding on that defendant's guilt. Such an assessment may require consideration of other evidence in order to determine whether mere deletion of the defenda”

   4 later decisions quote this exact passage · from the majority
   e.g. State v. Tucker · United States v. Benjamin Matthew Logan, Also Known as Matt Logan

3. “The interlocking of the confessions thus all but insured that a jury could identify the person referred to in McKenzie’s confession as Williams.... Nevertheless, a jury would identify Williams as the other “guy” in McKenzie’s confession only if it disregarded the limiting instructions given by the district court. As noted, Richardson stated that where linkage to other evidence is necessary to connect the defendant to the crime described in a codefendant’s confession, the likelihood that a jury will disregard such a limiting instruction is less than in a case such as Bruton, in which the codefendant’s confession directly and expressly implicated the defendant. Admission of McKenzie’s testimony was thus not error.”

   1 later decision quote this exact passage · from the majority
   e.g. 529 F. Supp. 2d 1315 - United States v. Lujan