Richardson v. Marsh (1986)
- Docket
- 85-1433
- Decided
- 1986-01-01
Summary
Question: In a joint trial, does the confession of one defendant without that defendant taking the stand violate the Confrontation Clause? Conclusion: No. Justice Antonin Scalia delivered the opinion of the 6-3 majority. The Court held that not only did the jury receive instructions not to consider the confession in assessing Marsh’s guilt, but also the confession was redacted so that there was no incriminating evidence regarding Marsh’s actions. Without the implication that the evidence in the confession was incriminating, Marsh’s Confrontation Clause rights were not violated. The Court also held that joint trials, while not necessarily in either defendant’s best interests from the perspective of the Confrontation Clause, are a necessary part of the justice system. Justice John Paul Stevens wrote a dissent and argued that the Confrontation Clause regulates the introduction of any evidence from which the jury could infer the defendant’s guilt. Given the presentation of the confession in this case, the jury could only infer that Williams’ confession also enumerated Marsh’s guilt. He also argued that the legal system’s interest in joint trials from an efficiency standpoint should not outweigh the defendant’s right to a fair trial. Justices William J. Brennan, Jr. and Thurgood Marshall joined in the dissent.