Saturday, November 2, 2013

Zafiro v. United States case brief

Zafiro v. United States case brief summary
506 U.S. 534 (1993)

Defendants were indicted and brought to trial together. Defendants all moved for severance, arguing that their defenses were mutually antagonistic. The district court denied defendants' motions for severance and they were convicted of various drug related charges. The court of appeals found that they had not suffered prejudice and affirmed the district court's judgment. Defendants sought further review by the Supreme Court.


  • Two of the four defendants were under surveillance when federal agents observed them carrying a large box. 
  • When the agents identified themselves, defendants dropped the box and ran into an apartment, belonging to one of the co-defendants. 
  • Upon entering the apartment, the agents found all four defendants there and after a search was conducted resulting in the seizure of illegal drugs they were all arrested. 
  • Defendants were brought to trial where they each brought motions for severance based upon mutually antagonistic defenses. Their motions were denied and they were convicted. 


  • The convictions were all upheld by the court of appeals. 
  • On further appeal, the Supreme Court upheld the court of appeals' judgment denying the motions for severance. 
  • The Court held that the defenses presented failed to rise to the level of mutual antagonism necessary for severance. 
  • The Court found that the government argued and offered sufficient evidence to find all four defendants guilty beyond a reasonable doubt of the crimes charged. 
  • The Court concluded that defendants were not entitled to a severance merely because they would have a better chance of acquittal in separate trials.

The Court affirmed the judgment denying defendants' motions for severance on the basis that the joint trial did not subject defendants to any legally cognizable prejudice.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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