Cruz v. New York

At 5:15 AM on November 29, 1981, Police Officers Dennis Fitzpatrick and Ronald Zuba responded to a radio report of an incident at the Gaseteria service station in Bronx County, New York.

[1] The following day, an associate medical examiner performed an autopsy on the deceased, which confirmed that two gunshot wounds were the cause of death.

The deceased showed further evidence of blunt force trauma to the bridge of the nose, area around the eyes, right cheek, and left shoulder.

[1] A grand jury sitting in New York Supreme Court, Bronx County, indicted Eulogio and Benjamin Cruz for felony murder and lesser offenses in connection with the homicide.

[1] Writing for the Court, Justice Scalia referenced Bruton v. United States, 391 U.S. 123 (1968), in laying out the question presented in the instant case.

In Bruton, the Court held that a defendant was deprived of his rights under the Confrontation Clause if a confession by his codefendant was introduced in their joint trial, regardless of whether the jury received instructions only to consider it against the confessor.

This guarantee, which is extended to defendants in state courts through the Fourteenth Amendment, includes the right to cross-examine witnesses.

But in the real world of criminal litigation, the defendant is seeking to avoid his confession—on the ground that it was not accurately reported, or that it was not really true when made.

Justice White rejected the notion that interlocking confessions would have the effect of "devastating" the other defendant's defense as outlined in Bruton.

This would overburden the state, inconvenience police and witnesses, cause delays in the trial system, and possibly lead to inconsistent verdicts, he continued.

Justice White concluded by pointing to other case law that suggests that a codefendant's interlocking confession will often be admissible against the defendant, negating the Confrontation Clause issue of Bruton.