Federal Defenders of New York Second Circuit Blog

Confrontation Clause

BYE-BYE, BRUTON?

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United States v. Williams, No. 05-6036-cr (2d Cir. October 23, 2007) (Newman, Walker, Straub, CJJ). In this curious but very troubling case, the court seems to have concluded, sub silentio, that Crawford trumps Bruton. Brothers Bobby and Michael Williams were tried for a drug-related triple homicide. Neither brother testified. At trial, over objection, the court … Read more

Crawford’s Eleven

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United States v. Becker, Docket No. 06-1274-cr (2d Cir. September 13, 2007) (Calabresi, Parker, Wesley, CJJ) At Becker’s stock fraud trial, the government introduced into evidence the plea allocutions of eleven (yes, eleven) of his co-defendants, supposedly for the “limited purpose” of establishing that the conspiracy charged in the indictment existed. The Circuit concluded that … Read more