Cruz v. New York Case Brief

Why is the case important?

“Eulogio Cruz (Petitioner) was arrested and, along with his brother Benjamin Cruz (co-defendant), tried and convicted of murder for the shooting of a gas station attendant. At trial, the prosecution called a witness who testified that Petitioner had confessed to the murder

  • the prosecution also introduced evidence of a tape-recorded confession that co-defendant had made to police. Petitioner appealed his conviction to the New York Court of Appeals, which affirmed, and Petitioner, on certiorari, appeals that decision here.”

    Facts of the case

    Question

    Was it a violation of Petitioner’s 6th amendment Confrontation Clause rights for the trial court to allow co-defendant’s videotaped confession to be admitted into evidence along with a limiting instruction given to the jury that it was not to use co-defendant’s confession in determining Petitioner’s guilt?

    Answer

    “Reversed and remanded. Yes

  • Petitioner’s 6th amendment Confrontation Clause rights were violated by the admission of co-defendant’s tape-recorded confession, despite the fact that Petitioner’s own confession interlocked with co-defendant’s, and despite the limiting instruction given by the trial judge to the jury.”

    Conclusion

    The court rejected the reasoning upon which the lower court had based its decision, and reversed and remanded for further proceedings. The court held that petitioner’s confession was not admissible under those circumstances. In instances such as this one where a nontestifying co-defendant’s confession incriminating petitioner was not directly admissible as evidence against petitioner, the co-defendant’s confession was not admissible during their joint trial, even if the jury was given a limiting instruction. The admission of such a statement would have violated the Confrontation Clause of U.S. Const. amend. VI . It was held that the confrontation clause of the Sixth Amendment bars the admission, at a joint criminal trial, of a nontestifying codefendant’s pretrial confession which incriminates the defendant and which is not directly admissible against the defendant, even though (1) the jury is instructed not to consider the confession against the defendant, and (2) the defendant’s own confession, corroborating that of the codefendant, is admitted against the defendant.

    • Case Brief: 1987
    • Petitioner: Cruz
    • Respondent: New York
    • Decided by: Rehnquist Court

    Citation: 481 US 186 (1987)
    Argued: Dec 1, 1986
    Decided: Apr 21, 1987