The Oyez Project: Criminal Procedure Issues - Confrontation Decisions

Agency Holding Corp. v. Malley-Duff & Assocs.

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Bank Of Nova Scotia v. United States

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Barber v. Page

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Becker v. Montgomery

When a party files a timely notice of appeal in district court, does the failure to sign the notice of appeal require the court of appeals to dismiss the appeal?

No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that when a party files a timely notice of appeal in district court, the failure to sign the notice does not require the court of appeals to dismiss the appeal. Justice Ginsburg wrote for the Court that "if the notice is timely filed and adequate in other respects, jurisdiction will vest in the court of appeals, where the case may proceed so long as the appellant promptly supplies the signature once the omission is called to his attention."

Brookhart v. Janis

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Bruton v. United States

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Bushnell v. Ellis

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Cahill v. New York, N. H. & H. R. Co.

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California v. Green

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California v. Superior Court Of California

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Carchman v. Nash

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Chambers v. Mississippi

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Coy v. Iowa

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Crawford v. Washington

Does playing out-of-court testimony to a jury, with no chance for cross-examination, violate a defendant's Sixth Amendment guarantee that "[i]n all criminal prosecutions, the accused shall enjoy the right...to be confronted with the witnesses against him?"

Yes. In a 9-0 opinion delivered by Justice Antonin Scalia, the Court sided with Crawford and ruled that the Sixth Amendment's Confrontation Clause gives defendants the right to confront witnesses and cross-examine their testimony. This includes testimony police gather. The Court reasoned that the Framers intended the Confrontation Clause to prohibit out-of-court testimony as evidence against defendants. By allowing out-of-court testimony if it was "reliable," the Roberts decision departed from the Framers' intent. The Court overruled Roberts. Chief Justice Rehnquist, joined by Justice Sandra Day O'Connor, concurred but opposed overruling Roberts.

Cruz v. New York

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Cuyler v. Adams

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Davis v. Alaska

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Davis v. Washington

Under the U.S. Supreme Court's interpretation of the Sixth Amendment in Crawford v. Washington, may statements made to police during investigation of a crime, though not made with the intent to preserve evidence, be admitted in court without allowing defendants to cross-examine the person who made the original statements?

Yes. In a 9-0 decision authored by Justice Antonin Scalia, the Court ruled that the Confrontation Clause of the Sixth Amendment, as interpreted in Crawford v. Washington, does not apply to "non-testimonial" statements not intended to be preserved as evidence at trial. Although McCottry identified her attacker to the 911 operator, she provided the information intending to help the police resolve an "ongoing emergency," not to testify to a past crime. The Court reasoned that under the circumstances, McCottry was not acting as a "witness," and the 911 transcript was not "testimony." Therefore, the Sixth Amendment did not require her to appear at trial and be cross-examined. Justice Clarence Thomas wrote a separate opinion concurring in part and dissenting in part. He argued that though McCottry's statements were not testimonial, the Court should not "guess" at the primary motive behind the statements. This case was decided with Hammon v. Indiana.

Degen v. United States

Should the fugitive disentitlement doctrine be extended to allow a court in a civil forfeiture suit to enter judgment against a claimant, without any opportunity to be heard, because the claimant is a fugitive from, or otherwise is resisting, a related criminal prosecution?

No. Principles of deference to the other branches of government require a court to invoke its inherent power only as a reasonable response to the problems and needs that provoke it. No sufficient reason justifies disentitlement here. Since the court's jurisdiction over the property is secure despite Degen's absence, there is no risk of delay or frustration in determining the merits of the government's forfeiture claims or in enforcing the resulting judgment. Also, the court has alternatives, other than disentitlement, to keep Degen from using liberal civil discovery rules to gain an improper advantage in the criminal prosecution, where discovery is more limited. Finally, disentitlement is an excessive response to the court's interests in redressing the indignity visited upon it by Degen's absence from the criminal proceeding, and in deterring flight from criminal prosecution in general; it is a response that erodes rather than enhances the dignity of the court.

Delaware v. Van Arsdall

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Demarest v. Manspeaker

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Douglas v. Alabama

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Dutton v. Evans

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Gomez v. United States

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Gray v. Maryland

Does Bruton v. United States apply to a redaction that replaces a name with an obvious blank space or a symbol or a word such as "deleted?"

Yes. In a 5-4 opinion delivered by Justice Stephen G. Breyer, the Court held that the confession, which substituted blanks and the word "delete" for the respondent's proper name, falls within the class of statements to which Bruton's protections apply. Applying Bruton, Justice Breyer wrote that a jury will often react to an unredacted confession and a confession redacted with the word "delete" similarly by realizing that the confession refers to the defendant. Justice Anton Scalia, joined by Chief Justice William H. Rehnquist and Justices Anthony M. Kennedy and Clarence Thomas, dissented. Justice Scalia argued that Bell's confession could constitutionally have been admitted with a limiting instruction to the jury.

Greene v. United States

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Haines v. Kerner

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Hammon v. Indiana

Yes. In an 8-1 decision authored by Justice Antonin Scalia, the Court ruled that the Confrontation Clause of the Sixth Amendment, as interpreted in Crawford v. Washington, does not apply to "non-testimonial" statements not intended to be preserved as evidence at trial. In Hammon's case, however, the Court ruled that Mrs. Hammon's statements to the police were testimonial. At the time of her questioning, Hammon faced "no emergency in progress" and "no immediate threat to her person." Instead, the relative safety of the conversation between Mrs. Hammon and the officer made it "formal enough" to qualify as a "testimonial" statement intended as evidence of the past crime. The Court left open the possibility that Hershel Hammon could have forfeited his constitutional right to confront the witnesses against him by coercively preventing his wife from testifying. Otherwise, however, the Court ruled that the Sixth Amendment did not allow Mrs. Hammon's testimony to be used against Mr. Hammon without her presence at the trial. Justice Clarence Thomas wrote a dissent criticizing the Court's test as unworkable. In Justice Thomas's view, Hammon's statement was not testimonial, because the conversation was not a "formalized dialogue." This case was decided along with Davis v. Washington.

Hampton v. United States

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Harrington v. California

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Honda v. Clark

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Houston v. Lack

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Idaho v. Wright

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Illinois v. Allen

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Jacobson v. United States

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Kentucky v. Stincer

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Klehr Et Ux. v. A. O. Smith Corp.

1)Does the time limit for filing a civil claim under the Racketeer Influenced and Corrupt Organizations Act of 1970 (RICO) begin after the plaintiff discovers the last illegal act ("last predicate act") at the end of a pattern of racketeering activity?

2)If the plaintiff demonstrates "fraudulent concealment" of the injury inflicted, can RICO's civil-claim limitations period be extended?

No and No. Justice Stephen Breyer wrote the opinion for a unanimous Court. The "last predicate rule...lengthens the limitations period dramatically" and thereby contradicts Congress's intention of ensuring a time limit for civil RICO claims. Also, "the plaintiff cannot use an independent, new act as a bootstrap to recover for injuries caused by other predicate acts that took place outside the limitations period."

RICO intends "not only to compensate victims but also to encourage those victims diligently to investigate and thereby to uncover unlawful activity." To demonstrate "fraudulent concealment", a plaintiff must have failed to discover injuries inflicted upon him after acting with "reasonable diligence" to discover the source and pattern of the injuries.

Lee Kum Hoy v. Murff

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Lee v. Illinois

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Lilly v. Virginia

Does trial evidence that includes out-of-court statements, that admit some wrongdoing but place primary blame on the defendant, by an alleged, nontestifying accomplice violate a criminal defendant's Sixth Amendment Confrontation Clause right to confront all adverse witnesses?

Yes. In an opinion delivered by Justice John Paul Stevens, the Court held that the admission of Mark's confession violated Benjamin's Confrontation Clause right "to be confronted with the witnesses against him." All nine justices voted to overturn the Virginia Supreme Court's decision that had allowed such hearsay testimony under an exception for statements made against penal interest. Justice Stevens wrote for a plurality that the confession could not be considered "sufficiently reliable as to be admissible without allowing [the defendant] to cross-examine him." Chief Justice William H. Rehnquist and Justices Antonin Scalia, Clarence Thomas and Stephen G. Breyer wrote concurring opinions.

Lurk v. United States

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Mancusi v. Stubbs

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Maryland v. Craig

Did the closed-circuit testimony violate the Confrontation Clause of the Sixth Amendment?

No. In a 5-to-4 decision, the Court held that the Confrontation Clause of the Sixth Amendment, which guarantees criminal defendants face-to-face meetings with witnesses against them at trial, was not absolute. The Court found that "in certain narrow circumstances, 'competing interests, if closely examined, may warrant dispensing with confrontation at trial." The State's interest in protecting the physical and psychological well-being of children, the Court held, could be sufficiently important to outweigh defendants' rights to face their accusers in court.

Masciale v. United States

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Mathews v. United States

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Mesarosh v. United States

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Michigan v. Lucas

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Moody v. Flowers

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Nelson v. O'neil

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New Mexico ex rel. Ortiz v. Reed

Did the Supreme Court of New Mexico err in upholding grant of state habeas corpus relief to parolee whom state of Ohio sought to extradite as alleged fugitive from justice by going beyond the scope of permissible inquiry?

Yes. In a unanimous per curiam opinion, the Court held that "the Supreme Court of New Mexico went beyond the permissible inquiry in an extradition case, and permitted the litigation of issues not open in the asylum State." The opinion stated, "this is simply not the kind of issue that may be tried in the asylum State. In case after case we have held that claims relating to what actually happened in the demanding State, the law of the demanding State, and what may be expected to happen in the demanding State when the fugitive returns, are issues that must be tried in the courts of that State, and not in those of the asylum State."

New Mexico v. Earnest

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New York v. Hill

Does a defense counsel's agreement to a trial date outside the 180-day time period required by Article III of the Interstate Agreement on Detainers waive the defendant's right to a speedy trial?

Yes. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that a defense counsel's agreement to a trial date outside the period provided for by the IAD bars the defendant from seeking dismissal on the ground that trial did not occur within that period. Noting scheduling matters are generally controlled by counsel without the fully informed and publicly acknowledged consent of the client, Justice Scalia wrote, "[w]hat suffices for waiver depends on the nature of the right at issue." In such cases, "[a]bsent a demonstration of ineffectiveness, counsel's word on such matters is the last." Thus, defense counsel's agreement to a later trial date waived Hill's speedy trial rights under the IAD.

North Star Steel Co. v. Thomas

Is state law the proper source of the limitations period for civil actions brought to enforce the Worker Adjustment and Retraining Notification Act?

Yes. In a 9-0 opinion delivered by Justice David H. Souter, the Court held that State law is the proper source of the limitations period for civil actions brought to enforce WARN. Where a federal statute fails to provide any limitations period for a new cause of action, the Court noted that its longstanding practice has been to borrow the limitations period from the most closely analogous state statute. The Court reasoned that North Star did not fall within the exception where the relevant state limitations periods would frustrate or interfere with the implementation of national policies or be at odds with the purpose or operation of federal substantive law. Justice Antonin Scalia concurred in the judgment.

Ohio v. Roberts

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Old Chief v. United States

Does a District Court have the authority to reject a defendant's offer to conceded a prior conviction and admit the prosecution's presentation of it when the name or nature of the conviction raises the risk of a verdict tainted by improper considerations, and when the purpose of the evidence is solely to prove the element of prior conviction?

No. In an opinion authored by Justice David Souter, the Court ruled that a district court abuses its discretion under the Federal Rules of Evidence if it spurns a defendant's offer to concede a prior judgment and admits the full judgment record over the defendant's objection, when the name or nature of the prior offense raises the risk of a verdict tainted by improper considerations, and when the purpose of the evidence is solely to prove the element of prior conviction.

Ortega-Rodriguez v. United States

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Parker v. Randolph

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Peretz v. United States

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Pointer v. Texas

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Puerto Rico v. Branstad

Do federal courts have the power to order governors to fulfill obligations under the Constitution's Extradition Clause in Article IV, Section 2?

Yes. The Court overturned its decision in Kentucky v. Dennison (1861) which had rendered federal courts powerless to enforce the Extradition Clause. The unanimous Court concluded that the precedent in Kentucky was "the product of another age" and "fundamentally incompatible with more than a century of constitutional development."

Ray v. United States

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Reno, Attorney General v. Koray

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Richardson v. Marsh

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Rock v. Arkansas

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Rogers v. United States

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Saldana v. United States

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Sampson v. Murray

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Schneble v. Florida

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Sherman v. United States

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Smith v. Illinois

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Specht v. Patterson

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Stirone v. United States

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Tacon v. Arizona

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Taylor v. Illinois

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Tennessee v. Street

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Thomas v. Arn

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Thompson v. Coastal Oil Co.

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Thompson v. I. N. S.

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United States v. Alvarez-Machain

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United States v. Alvarez-Sanchez

Does federal statute 18 U.S.C. Section 3501(c), declaring separate charge-based confessions inadmissible if obtained after the first six hours of detention, apply to suspects that are held only on state or federal charges?

No. In a unanimous decision, the Court held that the provisions of the federal statute in question do not apply to suspects being held solely on state charges. The Court explained that no delay is said to occur until the suspect is arrested and detained for a federal crime. The six-hour period only begins to expire from the point of a suspect's federal arrest and charging. In this case, Alvarez-Sanchez was presented before a federal judge within six hours of his arrest on a federal counterfeit charge. The fact that he was held for some two and a half days prior has no bearing on his federal status under the statute since he was detained on state and local charges only during this time.

United States v. Dunnigan

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United States v. France

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United States v. Inadi

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United States v. Massei

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United States v. Owens

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United States v. Powell

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United States v. Recio

Is the Ninth Circuit rule -- that a conspiracy ends automatically when the object of the conspiracy becomes impossible to achieve -- valid?

No. In a 9-0 opinion delivered by Justice Stephen G. Breyer, the Court held that a conspiracy does not automatically terminate simply because the federal government has defeated its object, such that Ninth Circuit's conspiracy-termination law is erroneous. Justice Breyer stated that the Ninth Circuit's rule is inconsistent with basic conspiracy law and that the agreement to commit an unlawful act is "'a distinct evil,'" which "'may exist and be punished whether or not the substantive crime ensues.'" Justice John Paul Stevens filed an opinion concurring in part and dissenting in part.

United States v. Russell

Does an undercover law enforcement officer's participation in criminal conduct constitute entrapment in violation of the Fifth Amendment's due process protections?

Not always. In a 5-to-4 decision, the Court held that law enforcement officers may participate in the procedural commission of certain crimes such as drug manufacturing, so long as they do not implant criminal designs in the minds of the accused. In Russell's case, the investigated drug operations were in place long before undercover agents infiltrated them. Moreover, the ingredients contributed by the agents could have been acquired independently by Russell and his co-conspirators. As such, none of the agents' participatory activities amounted to entrapment.

United States v. Salerno

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United States v. Scheffer

Does Military Rule of Evidence 707, excluding the admission of polygraph results into evidence, violate a defendant's Sixth Amendment right to present a fair defense?

No. In an 8-to-1 decision, the Court held that Rule 707 was consistent with the legitimate interest of state and federal authorities to admit only reliable evidence. In addition to noting the even-handed scope of Rule 707, excluding from evidence both favorable and unfavorable polygraph results, the Court emphasized the poor reliability of polygraph evidence as a whole. In the absence of sounder detection methods, the Court noted that the fundamental premise of the criminal justice system is that juries are the ultimate and most reliable evaluators of credibility and truthfulness.

United States v. Shotwell Mfg. Co.

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United States v. Valenzuela-Bernal

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United States v. Williams

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United States v. Wilson

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Washington v. Texas

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White v. Illinois

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