Richardson v. Marsh case brief

Richardson v. Marsh case brief summary
481 U.S. 200 (1987)

CASE SYNOPSIS

Petitioner prison warden challenged a judgment of the United States Court of Appeals for the Sixth Circuit which reversed a district court judgment denying respondent inmate's petition for a writ of habeas corpus pursuant to 28 U.S.C.S. § 2254. Respondent's state court convictions for felony murder in the perpetration of an armed robbery and assault with intent to commit murder were affirmed on direct appeal.

CASE FACTS
Respondent inmate and a codefendant were tried together, and the codefendant's confession, redacted to omit any reference to respondent, was admitted. The codefendant did not testify and the jury was given a limiting instruction. Respondent's convictions for felony murder and assault with intent to commit murder were affirmed on appeal. The court of appeals reversed a district court order denying respondent's habeas corpus petition.

DISCUSSION

• Petitioner warden sought a writ of certiorari and the Court reversed. 
• The introduction of the codefendant's confession did not violate the Confrontation Clause of the Sixth Amendment because it was proper to presume that the jury would obey the limiting instruction. 
• The improbability that a jury would be able to disregard a codefendant's expressly incriminating confession did not apply to a confession from which every reference to respondent had been redacted. 
• On remand, the lower court was directed to consider whether the prosecutor's comments seeking to undo the limiting instruction by urging the jury to use the confession against respondent served as a basis for the writ of habeas corpus in light of respondent's failure to object.

CONCLUSION

The Court reversed the judgment, which had reversed a district court judgment denying respondent inmate's petition for habeas corpus. The admission of a codefendant's confession in respondent's joint trial did not violate the Confrontation Clause because every reference to respondent was redacted and the jury was properly presumed to have followed its limiting instruction. The case was remanded with directions.

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