Tennessee v. Street

Background

A neighbor of the victim, accused of murder after a body was found hanging, gave a detailed confession that he later said was coerced and copied from an accomplice’s written statement. The State called the sheriff to deny coercion and, to rebut the defendant’s claim that his confession was a copied imitation, the sheriff read the accomplice Peele’s out-of-court written confession to the jury. The trial judge warned the jury that Peele’s statement was admitted only for rebuttal and not to prove the truth of the events described.

Reasoning

The central question was whether letting the jury hear an accomplice’s confession for the limited purpose of rebutting the defendant’s testimony violated the defendant’s right to cross-examine witnesses. The Court explained that the confession was not used as proof of what happened at the crime scene but only to show what happened when the defendant made his confession. Because the sheriff who read the statement was on the stand and subject to cross-examination, and because no workable alternative would have served the State’s need to rebut, the Court held the limited admission did not breach the right to cross-examine.

Real world impact

The decision allows prosecutors to use an accomplice’s out-of-court confession to counter a defendant’s claim that his confession was copied, provided the use is narrowly limited and the in-court witness can be cross-examined. The ruling emphasizes trial judges’ limiting instructions but recognizes a real risk of jury misuse.

Dissents or concurrances

Justice Brennan, joined by Justice Marshall, agreed with the result but stressed that such admission is permissible only when truly essential and when no adequate alternative exists; limiting instructions alone are not always enough.