Parker v. Randolph, 442 U.S. 62 (1979)

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Author: U.S. Supreme Court

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Parker v. Randolph, 442 U.S. 62 (1979)

Parker v. Randolph


No. 78-99


Argued March 20, 1979
Decided May 29, 1979
442 U.S. 62

CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT

Syllabus

Respondents were convicted, after a joint trial in a Tennessee court, of murder committed during the commission of a robbery. None of the respondents took the witness stand, and their oral confessions, found by the trial court to have been freely and voluntarily given, were admitted into evidence through police officers’ testimony. Respondent Pickens’ written confession was also admitted into evidence over his objection that it had been obtained in violation of his rights under Miranda v. Arizona, 384 U.S. 436. The trial court instructed the jury that each confession could be used only against the defendant who gave it and could not be considered as evidence of a codefendant’s guilt. Ultimately, the Tennessee Supreme Court upheld the convictions, holding that admission of respondents’ confessions did not violate the rule of Bruton v. United States, 391 U.S. 123, which held that a defendant’s rights under the Confrontation Clause of the Sixth Amendment were violated by the admission, at a joint trial, of the confession of a codefendant who did not take the stand. Respondents subsequently obtained writs of habeas corpus in a Federal District Court, which held that respondents’ rights under Bruton had been violated, and that introduction of respondent Pickens’ written confession had violated his rights under Miranda. The Court of Appeals affirmed.

Held: The judgment is affirmed as to respondent Pickens and reversed as to the other respondents. Pp. 69-77; 77-81.

575 F.2d 1178, affirmed in part and reversed in part.

MR. JUSTICE REHNQUIST delivered the opinion of the Court with respect to Parts I and III, concluding that, since the grant of certiorari was limited to the Bruton issue, the Court had no occasion to pass on the merits of the ruling that respondent Pickens’ rights under Miranda had been violated. Pp. 76-77.

MR. JUSTICE REHNQUIST, joined by THE CHIEF JUSTICE, MR. JUSTICE STEWART, and MR. JUSTICE WHITE, concluded, in Part II, that admission of respondents’ confessions with proper limiting jury instructions did not infringe respondents’ right of confrontation secured by the Sixth and Fourteenth Amendments. Pp. 69-76.

(a) In Bruton, introduction at a joint trial of a nontestifying codefendant’s confession had a "devastating" effect on the nonconfessing defendant’s case. Introduction of such incriminating extrajudicial statements of a codefendant will seldom, if ever, have the same "devastating" consequences to a defendant who has himself confessed. The constitutional right of cross-examination protected by Bruton has far less practical value to a defendant who has confessed to the crime than to one who has consistently maintained his innocence. Pp. 72-73.

(b) Nor does the natural "motivation to shift blame onto others," recognized in Bruton to render the incriminating statements of codefendants "inevitably suspect," require application of the Bruton rule when the incriminated defendant has corroborated his codefendant’s statements by heaping blame onto himself. P. 73.

(c) The Confrontation Clause does not bar admission into evidence of every relevant extrajudicial statement by a nontestifying declarant simply because it in some way incriminates the defendant. And an instruction directing the jury to consider a codefendant’s extrajudicial statement only against its source is generally sufficient to avoid offending the implicated defendant’s confrontation right. Pp. 73-74.

(d) When the defendant’s own confession is properly before the jury, as here, the possible prejudice resulting from the jury’s failure to follow the trial court’s instructions is not so "devastating" or "vital" to the confessing defendant as to require departure from the general rule allowing admission of evidence with limiting instructions. Pp. 74-75.

MR. JUSTICE BLACKMUN would not find the rule of Bruton to be inapplicable simply because interlocking confessions are involved. Rather, even where the confessions of nontestifying codefendants overlap to some degree, he would follow the analysis indicated by Bruton and then determine whether the error was harmless beyond a reasonable doubt. On the facts of this case, he concludes that any error was clearly harmless beyond a reasonable doubt. Pp. 77-81.

REHNQUIST, J., announced the Court’s judgment and delivered an opinion of the Court with respect to Parts I and III, in which BURGER, C.J., and STEWART, WHITE, and BLACKMUN, JJ., joined, and an opinion with respect to Part II, in which BURGER, C.J., and STEWART and WHITE, JJ., joined. BLACKMUN, J., filed an opinion concurring in part and concurring in the judgment, post, p. 77. STEVENS, J., filed a dissenting opinion, in which BRENNAN and MARSHALL, JJ., joined, post, p. 81. POWELL, J., took no part in the consideration or decision of the case.

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Chicago: U.S. Supreme Court, "Syllabus," Parker v. Randolph, 442 U.S. 62 (1979) in 442 U.S. 62 442 U.S. 63–442 U.S. 64. Original Sources, accessed September 18, 2018, http://www.originalsources.com/Document.aspx?DocID=D1BUULXCCYRP4TW.

MLA: U.S. Supreme Court. "Syllabus." Parker v. Randolph, 442 U.S. 62 (1979), in 442 U.S. 62, pp. 442 U.S. 63–442 U.S. 64. Original Sources. 18 Sep. 2018. www.originalsources.com/Document.aspx?DocID=D1BUULXCCYRP4TW.

Harvard: U.S. Supreme Court, 'Syllabus' in Parker v. Randolph, 442 U.S. 62 (1979). cited in 1979, 442 U.S. 62, pp.442 U.S. 63–442 U.S. 64. Original Sources, retrieved 18 September 2018, from http://www.originalsources.com/Document.aspx?DocID=D1BUULXCCYRP4TW.