Does a post-arrest statement need to be admitted to incriminate another codefendant?
MultiRegion, United States of America
The following excerpt is from U.S. v. Martinez, 5 F.3d 542 (9th Cir. 1993):
Generally, a codefendant's post-arrest statement may not be admitted to incriminate another codefendant. Bruton v. United States, 391 U.S. 123 (1968). We review allegations of Bruton errors de novo. United States v. Reyes-Alvarado, 963 F.2d 1184, 1187 (9th Cir.), cert. denied, 113 S.Ct. 258 (1992). We find that Bruton is not implicated here, and that the cautionary instructions were sufficient to cure any error in the dissemination of the transcripts.
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