Criminal Procedure keyed to Kamisar
Gray v. Maryland
Facts
In 1993, Bell and Gray were tried jointly for the murder of Stacey Williams. Bell refused to testify and his confession was entered against him at trial. According to the Judge’s Order, when the confession was read, the name of Gray was to be deleted and, instead the word “deleted” was to be used. The jury convicted both parties and Gray appealed. The intermediate appellate court applied Bruton v. United States (391 U.S. 23), which held that a jury should consider a confession only against the confessing codefendant and the introduction of such a confession at a joint trial is a violation of the nonconfessing defendant’s sixth amendment right to cross-examine witnesses. The conviction was later reinstated by the Maryland Supreme Court, and cert was taken to the United States Supreme Court.
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