Samia v. United States
The Supreme Court ruled that a co-defendant's confession can be admitted at a joint trial when the defendant's name has been replaced with a neutral phrase like 'the other person' and jurors are instructed to use it only against the person who confessed.
The decision declines to extend a landmark 1968 precedent that bars admitting a co-defendant's confession naming the defendant, drawing a constitutional line between confessions that directly accuse and those that implicate only through inference — a distinction the three dissenters say invites prosecutors to easily circumvent defendants' confrontation rights.
“The Confrontation Clause ensures that defendants have the opportunity to confront witnesses against them, but it does not provide a freestanding guarantee against the risk of potential prejudice that may arise inferentially in a joint trial.”
The majority's statement of what the Confrontation Clause does and does not protect in a joint trial.
How it got here: A federal trial court in the Southern District of New York convicted Samia on all counts; the Second Circuit affirmed; Samia asked the Supreme Court to step in and the Court agreed to hear the case.
The Case in Depth
What happened
Adam Samia, Joseph Hunter, and Carl Stillwell were arrested for carrying out a murder-for-hire in the Philippines on behalf of a crime boss. After his arrest, Stillwell confessed to federal agents that he drove the van while Samia shot the victim twice in the face. Because Stillwell chose not to testify at trial, the government had a DEA agent read a modified version of the confession to the jury — replacing Samia's name with phrases like "the other person" — while the judge told jurors the confession could only be used against Stillwell.
The question before the Court
Could prosecutors at a joint criminal trial use a co-defendant's confession — with the defendant's name swapped out for "the other person" — as long as the jury was told not to use it against the defendant?
The Court's answer
No — the Confrontation Clause was not violated. When a co-defendant's confession has been modified to remove the defendant's name and replace it with a neutral phrase, and the jury is properly instructed to consider it only against the person who confessed, the non-confessing defendant's right to confront witnesses has not been denied.
The Court drew the constitutional line between confessions that directly accuse a defendant and those that implicate him only through inference. A confession using the defendant's actual name, or replacing it with an obvious signal of omission like a blank space or the word "deleted," crosses into direct accusation and cannot be saved by a limiting instruction under the Court's 1968 Bruton rule. But swapping a name for a neutral phrase like "the other person" falls on the other side of that line — it becomes incriminating only when the jury connects it to other evidence, and in that setting a limiting instruction is presumed sufficient to prevent improper use.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Prosecutors trying multiple defendants together can now admit a co-defendant's confession by replacing the defendant's name with a neutral placeholder, without needing to hold separate trials. For defendants in joint cases, it becomes harder to challenge a confession that clearly points at them but doesn't use their name, even when the jury could easily figure out who is meant.
What changes now
Samia's conviction stands and he continues to serve a sentence of life plus 10 years in prison. For federal and state courts, the ruling means prosecutors can use a redacted co-defendant's confession in a joint trial as long as the defendant's name is replaced with a neutral placeholder and the jury is given a limiting instruction. The Bruton rule remains in force for confessions that explicitly name a defendant or use obvious stand-ins like blank spaces or the word "deleted."
What this does not decide
The Court did not decide whether rewriting — rather than just redacting — a confession is always a permissible method of modification. It also left open broader questions about how much a court must consider the surrounding trial context when evaluating whether a modified confession directly implicates a defendant.
Concurrences and dissents
How the Justices voted
Majority (5). Justice Thomas (author), joined by Justice Roberts, Justice Alito, Justice Gorsuch, and Justice Kavanaugh.
Separate writings (1). Justice Barrett (author of a concurrence (in part)).
Dissent (3). Justice Kagan (author), joined by Justice Sotomayor and Justice Jackson.
Concurrence in part — Justice Barrett
Justice Barrett agreed that the modified confession did not violate the Confrontation Clause, but wrote separately to reject the majority's reliance on 19th-century evidentiary practice in Part II-A. She argued that evidence from the late 1800s and early 1900s comes too late to shed light on the Clause's original meaning, and that many of the cited cases addressed ordinary hearsay rules rather than constitutional confrontation rights. She would have decided the case without drawing on that historical record.
Dissent — Justice Kagan
Justice Kagan argued the majority elevated form over substance by treating a neutral-phrase placeholder as constitutionally different from a blank space or 'deleted,' when both point just as directly at the defendant. Under Bruton, she wrote, what matters is the confession's inculpatory impact on the jury — not the precise wording of the redaction. She warned the decision gives prosecutors a ready tool to circumvent Bruton's protections entirely, reducing the Confrontation Clause in joint trials to a shell.
Dissent — Justice Jackson
Justice Jackson joined Justice Kagan's dissent in full and wrote separately to challenge the majority's framing of Bruton as a 'narrow exception' to a default rule of admissibility. She argued the correct baseline is that a testimonial co-defendant confession is presumptively inadmissible; the burden falls on the government to justify an exception, not on the defendant to show exclusion is required. By inverting this principle, she wrote, the majority sets the stage for systematic erosion of Confrontation Clause rights in joint trials. Read the full dissent →
How the Court got there
The legal reasoning, step by step
- The Confrontation Clause covers testimonial statements — including a formal, recorded confession given after Miranda warnings — but applies only to witnesses 'against' the defendant. Under the Court's general rule, a co-defendant's statement introduced at a joint trial is not considered 'against' a non-confessing defendant if the jury is instructed to use it only against the confessor. This presumption that jurors follow limiting instructions is the default starting point.
- In Bruton v. United States (1968), the Court carved out a narrow exception: when a co-defendant's confession 'facially incriminates' the defendant — as when it names him directly — a limiting instruction cannot be trusted to undo the damage, because the risk that jurors will improperly rely on it is simply too great. That exception applies only to directly accusatory confessions.
- In Richardson v. Marsh (1987), the Court declined to extend Bruton to confessions that become incriminating only when later evidence connects them to the defendant — so-called inferential incrimination. In that setting, the limiting instruction has a better chance of working because the jury must travel a chain of reasoning before arriving at the incriminating conclusion.
- In Gray v. Maryland (1998), the Court refined the boundary: confessions redacted by substituting a blank space or the word 'deleted' for the defendant's name are still 'directly accusatory' under Bruton, because jurors will immediately recognize the stand-in and look straight at the defendant sitting at counsel table. But Gray affirmed that confessions incriminating only 'by connection' to later evidence remain outside Bruton's scope.
- Applying this framework to Stillwell's modified confession, the Court held that replacing Samia's name with 'the other person' was not an obviously redacted signal in the manner of a blank or 'deleted.' The phrase was a neutral one that did not itself point a finger directly at Samia; any incrimination required the jury to connect the phrase to surrounding evidence — squarely in Richardson's territory, where a limiting instruction is presumed adequate.
- Extending Bruton to cover any modification a jury might decode from context would effectively require separate trials whenever the government wants to use a co-defendant's confession, since all prosecution evidence in a joint trial is mutually reinforcing. The Court rejected that outcome as an unnecessary and impractical disruption to the established role of joint trials in the criminal justice system.
Doctrinal impact
Cases affected by this decision
Distinguishes Bruton v. United States (391 U.S. 123)
Bruton applies only to confessions directly naming or obviously signaling a defendant; Stillwell's neutral-phrase redaction falls outside its reach.
Reaffirms Richardson v. Marsh (481 U.S. 200)
Richardson's refusal to extend Bruton to confessions that incriminate only by connection to later evidence controls the outcome here.
Distinguishes Gray v. Maryland (523 U.S. 185)
Gray covers obviously redacted confessions with blank spaces or 'deleted'; a neutral phrase like 'the other person' is not similarly obvious.