GRAY V. MARYLAND
523 U.S. 185 (1998)
NATURE OF THE CASE: This was a dispute over the use of a redacted confession in a joint trial.
FACTS: Bell confessed to police that he, Gray (D) and another, Vanlandingham, had participated in the beating death of Stacey Williams. Bell and D were indicted for murder. The trial judge denied D's motion for a separate trial. The trial judge also permitted the State to introduce Bell's confession with redactions by substituting in the place of the name, a blank space or the word deleted. Immediately after the police detective read the redacted confession to the jury, the prosecutor asked, 'after he gave you that information, you subsequently were able to arrest Mr. Kevin Gray; is that correct?' The officer responded, 'That's correct.' When instructing the jury, the trial judge specified that the confession was evidence only against Bell; the instructions said that the jury should not use the confession as evidence against D. D was convicted and appealed. Maryland's intermediate appellate court accepted D's argument that Bruton prohibited use of the confession and set aside his conviction. Maryland's highest court disagreed and reinstated the conviction.
ISSUE:
RULE OF LAW:
HOLDING AND
DECISION:
LEGAL ANALYSIS:
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