Samia v. United States

Whether the Confrontation Clause bars the admission of a nontestifying codefendant’s confession where (1) the confession has been modified to avoid directly identifying the nonconfessing codefendant and (2) the court offers a limiting instruction that jurors may consider the confession only with respect to the confessing codefendant.

Petitioner, Samia, was charged in a multicount indictment for his alleged involvement in several crimes related to a murder-for-hire. Stillwell, who was another one of the three men involved in the scheme, confessed his participation during a post arrest interview with DEA agents. The Government tried all three men jointly in the Southern District of New York, where Samia denied any participation. The District Court granted the Government’s motion in limine to admit Stillwell’s confession but required alterations to be made consistent with Confrontation Clause precedents. The jury convicted Samia and his codefendants on all counts. The District Court sentenced Samia to life plus 10 years, which Samia then appealed to the Second Circuit. On appeal, Samia argued that admission of Stillwell’s confession was constitutional error because other evidence and statements at trial enabled the jury to immediately infer that the “other person” described in the statement was Samia. The Second Circuit rejected this and held that the admission of the confession did not violate Samia’s Confrontation Clause rights. The Supreme Court granted certiorari to determine whether the admission of Stillwell’s altered confession violated Samia’s Confrontation Clause rights. Petitioner argued that despite the alterations made to the confession, when combined with other evidence, the statements describing the “other person” nonetheless implicated Samia’s involvement. Additionally, he argued that certain statements made by the Government would allow the jury to infer that he was the “other person” referred to in Stillwell’s confession.