United States v. Gonzalez

698 F. Supp. 531, 1988 U.S. Dist. LEXIS 12502, 1988 WL 119983
CourtDistrict Court, S.D. New York
DecidedNovember 9, 1988
DocketNo. 88 Cr. 630 (PKL)
StatusPublished

This text of 698 F. Supp. 531 (United States v. Gonzalez) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Gonzalez, 698 F. Supp. 531, 1988 U.S. Dist. LEXIS 12502, 1988 WL 119983 (S.D.N.Y. 1988).

Opinion

MEMORANDUM DECISION AND ORDER

LEISURE, District Judge.

The three defendants to this action are charged in a single count indictment with distribution of a Schedule II controlled substance, in violation of 18 U.S.C. §§ 812, 841(a)(1), 841(b)(1)(C), and 18 U.S.C. § 2. Defendant Carlos Colon (“Colon”) has moved for a severance under Federal Rule of Criminal Procedure 14. Defendant Angel Rosario (“Rosario”) has joined in that application. Defendant Hector Gonzalez (“Gonzalez”) does not make a severance application. For the following reasons, the defendants’ motions are denied.

Generally, where “defendants ... are jointly indicted [they] should be jointly tried.” United States v. Ventura, 724 F.2d 305, 812 (2d Cir.1983). This is particularly true where the crime charged involves a common scheme or plan. United States v. Turoff, 853 F.2d 1037 (2d Cir.1988); United States v. Girard, 601 F.2d 69, 72 (2d Cir.), cert. denied, 444 U.S. 871, 100 S.Ct. 148, 62 L.Ed.2d 96 (1979). The Supreme Court has unequivocally recognized that “[j]oint trials play a vital role in the criminal justice system.” Richardson v. Marsh, 481 U.S. 200, 107 S.Ct. 1702, 1708, 95 L.Ed.2d 176 (1987).

The propriety of joinder in the abstract is not seriously challenged here, but defendant Colon argues that specific post-arrest statements by defendants Rosario and Hector Gonzalez (“Rosario statement” and “Gonzalez statement”) will, upon their introduction at trial and the anticipated refusal of those defendants to testify, violate Colon’s Sixth Amendment confrontation clause rights under Bruton v. United States, 391 U.S. 123, 88 S.Ct. 1620, 20 L.Ed.2d 476 (1968). Additionally, the anticipated defenses of Colon and the other defendants are said to be so antagonistic as to require a severance.

A. Confrontation Rights and Bruton.

As an initial matter the Court notes that motions. to sever under Fed.R.Crim.P. 14 are “committed to the sound discretion of the trial judge,” and that it is the defendant’s "heavy burden” to:

show facts demonstrating that he will be so severely prejudiced by a joint trial that it would in effect deny him a fair trial. The defendant must demonstrate that he suffered such prejudice as a result of joinder, not that he might have had a better chance for acquittal at a separate trial.

United States v. Chang An-Lo, 851 F.2d 547, 557 (2d Cir.1988) (citations omitted). See also, United States v. Bari, 750 F.2d 1169, 1177 (2d Cir.1984) (burden of showing substantial prejudice “amounting to a miscarriage of justice,”), cert. denied sub [533]*533nom. Benfield v. United States, 472 U.S. 1019, 105 S.Ct. 3482, 87 L.Ed.2d 617 (1985); United States v. Wilkinson, 754 F.2d 1427, 1435 (2d Cir.) (same), cert. denied sub nom. Shipp v. United States, 472 U.S. 1019, 105 S.Ct. 3482, 87 L.Ed.2d 617 (1985); United States v. Potamitis, 739 F.2d 784, 791 (2d Cir.) (same), cert. denied 469 U.S. 934, 105 S.Ct. 332, 83 L.Ed.2d 269 (1984).

The admission at a joint trial of a co-defendant’s statement that implicates the other defendant can constitute prejudicial error, notwithstanding any cautionary instructions that might be given to the jury. Bruton v. United States, 391 U.S. 123, 137, 88 S.Ct. 1620, 1628, 20 L.Ed.2d 476 (1968). The rationale behind this proscription is, partly, that such “incrimina-tions are devastating to the defendant and their credibility inevitably suspect.” Id. at 136, n. 12, 88 S.Ct. at 1628, n. 12. Colon argues, and the Court agrees, that the un-redacted statements made by Rosario and Gonzalez would fall within the statements contemplated by Bruton. See, Cruz v. New York, 481 U.S. 186, 107 S.Ct. 1714, 95 L.Ed.2d 162 (1987).

The government, however, offers to seek to admit only redacted versions of the Rosario and Gonzalez statements. See, Exhibits C and D, attached to Government’s Memorandum of Law in Oppostion to the Severance Motions. This does not, however, automatically eliminate a confrontation clause problem. Redacted statements of a non-testifying co-defendant can still violate the defendant’s Sixth Amendment rights if the statement is both clearly incul-patory and vitally important to the government’s case against the defendant. United States v. Knuckles, 581 F.2d 305, 313 (2d Cir.), cert. denied, 439 U.S. 986, 99 S.Ct. 581, 58 L.Ed.2d 659 (1978); United States v. Wilkinson, 754 F.2d 1427 (2d Cir.1985).

The proposed redacted statements in the present ease are not, themselves, clearly inculpatory to the defendant Colon. The proposed redactions eliminate all reference to Colon, and eliminate all physical descriptions that might explicitly implicate Colon. The statements, to violate the Bru-ton rule, must be clearly inculpatory standing alone. United States v. Burke, 700 F.2d 70, 85 (2d Cir.), cert. denied, 464 U.S. 816, 104 S.Ct. 72, 78 L.Ed.2d 85 (1983). “Where, as here, the inculpatory impact upon the defendant of the statements is defused because it depends upon other prosecution evidence to connect the defendant to the subject of the statements, the Bruton rule is not violated.” United States v. Slocum, 695 F.2d 650, 655 (2d Cir.1982), cert. denied, 460 U.S. 1015, 103 S.Ct. 1260, 75 L.Ed.2d 487 (1983). See also, United States ex rel.

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Related

Bruton v. United States
391 U.S. 123 (Supreme Court, 1968)
Cruz v. New York
481 U.S. 186 (Supreme Court, 1987)
Richardson v. Marsh
481 U.S. 200 (Supreme Court, 1987)
United States v. Alfred Carpentier
689 F.2d 21 (Second Circuit, 1982)
United States v. Robert W. Slocum
695 F.2d 650 (Second Circuit, 1982)
United States v. Armand Ventura
724 F.2d 305 (Second Circuit, 1983)
United States v. Chang An-Lo
851 F.2d 547 (Second Circuit, 1988)
United States v. Wilkinson
754 F.2d 1427 (Second Circuit, 1985)
Arnold v. Coakley
401 U.S. 917 (Supreme Court, 1971)
Mosley v. United States Department of Labor
439 U.S. 986 (Supreme Court, 1978)
Vilato v. United States
469 U.S. 934 (Supreme Court, 1984)

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Bluebook (online)
698 F. Supp. 531, 1988 U.S. Dist. LEXIS 12502, 1988 WL 119983, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-gonzalez-nysd-1988.