Brown v. Greene

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In 2001, Mary Edmond was shot near a North Philadelphia gas station. She died from her injuries. During the investigation, Garcia gave a confession to the police that was self-incriminating, but indicated that Lambert pulled the trigger. When Lambert and Garcia are jointly tried in Pennsylvania state court, Garcia declined to testify, depriving Lambert of the ability to cross-examine him about the confession. The judge redacted the confession in an effort to comply with the Supreme Court holding in Bruton v. United States (1968). When the jury heard Garcia’s confession, Lambert’s name was replaced with terms like “the other guy.” During closing arguments, however, the prosecutor made statements that the defense believed revealed that Lambert was “the other guy.” The judge denied a motion for mistrial, but instructed the jury that the confession could only be used against Garcia and must not be considered as evidence against Lambert. Both were convicted. The Third Circuit reversed and granted habeas relief, based on the Sixth Amendment violation caused by the closing arguments. The error was not harmless. View "Brown v. Greene" on Justia Law