Gray v. Maryland

Anthony Bell confessed to the police that he and Kevin Gray (defendant) had beaten a man to death. The United States (plaintiff) charged Bell and Gray with murder. The district court tried Bell and Grey jointly and admitted Bell’s confession into evidence. However, the judge ordered that Gray’s name be redacted. Thus, when the police officer read Bell’s statement into evidence, he replaced Gray’s name with the word “deleted” or “deletion.” After the officer read the confession, the prosecutor asked him whether the information he received from Bell allowed him to then go and arrest Gray. The officer answered in the affirmative. The prosecution also admitted a written copy of the confession into evidence. Gray’s name was again redacted. In its place was a blank space separated by commas. The judge instructed the jury that the confession was evidence against Bell, not Gray. The jury convicted both men. Maryland's intermediate appellate court set aside Gray's convicted and applied Bruton v. United States, 391 U.S 123 (1968). In Bruton, the court held that, even if a court offers a limiting instruction telling the jury that it should consider a confession as evidence only against the confessing codefendant, introducing such a confession at a joint trial violates the nonconfessing defendant's right to cross-examine witnesses under the Sixth Amendment. The of Court of Appeals of Maryland, Maryland's highest court, reinstated the conviction. The United States Supreme Court granted certiorari.