confession

Corley v. United States

Issues

Whether federal law requires that a confession  taken  more than six hours after a defendant's arrest, and before the defendant appears before the magistrate judge, must be suppressed if there was unreasonable delay in bringing the defendant before the judge.

 

When Johnnie Corley was arrested for assaulting an officer and interrogated about the robbery of a credit union, he did not confess to a role in the robbery until more than six hours after his arrest. Moreover, Corley did not appear before a magistrate judge until the next day. After the District Court found Corley guilty, the Third Circuit affirmed. Corley is now appealing to the Supreme Court of the United States. His case will determine whether, if there was unreasonable delay in bringing a suspect before a magistrate judge, the suspect's confession is still valid. The Supreme Court's decision will affect suspects' rights and the procedure that police must follow during a confession.

 

    Questions as Framed for the Court by the Parties

    Whether 18 U.S.C. § 3501 - read together with Fed. R. Crim. P. Rule 5(a), McNabb v. United States, 318 U.S. 332 (1943), and Mallory v. United States, 354 U.S. 449 (1957) - requires that a confession taken more than six hours after arrest and before presentment be suppressed if there was unreasonable or unnecessary delay in bringing the defendant before the magistrate judge.

    Federal law enforcement officials identified Johnnie Corley as one of three men who robbed the Norsco Federal Credit Union in Norristown, Pennsylvania, on June 16, 2003. See U.S. v. Corley, 500 F.3d 210, 212 (3d Cir.

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    Samia v. United States

    Issues

    Is a criminal defendant’s Sixth Amendment Confrontation Clause right violated by allowing into evidence a co-defendant’s redacted out-of-court confession that immediately incriminates the defendant due to the surrounding context?

    This case asks the Supreme Court to determine whether admitting a co-defendant's redacted out-of-court confession that immediately inculpates a defendant based on the surrounding context results in a Confrontation Clause violation. Adam Samia was convicted of murder and other criminal charges at a joint trial after the United States introduced as evidence the redacted confession of Samia’s co-defendant that mentioned and described an accomplice. Samia argues that admitting his co-defendant’s confession violated his Sixth Amendment Confrontation Clause right because the jury likely inferred that he was the unidentified accomplice in his co-defendant’s confession. Samia asserts that under the Supreme Court’s decision in Bruton v. United States, his co-defendant’s confession should have been excluded. The United States counters that no Sixth Amendment violation occurred, and the co-defendant’s confession was properly admitted because, consistent with Bruton, all references to Samia were redacted and a limiting instruction was given. This case has significant implications for the role of trial judges as gatekeepers, prosecutorial discretion and power, and the scope of protection the Sixth Amendment provides.

    Questions as Framed for the Court by the Parties

    Whether admitting a co-defendant’s redacted out-of-court confession that immediately inculpates a defendant based on the surrounding context violates the defendant’s rights under the Confrontation Clause of the Sixth Amendment.

    Adam Samia was employed as a security guard and, in 2011, traveled to the Philippines to work for a company called Echelon Associates. Brief for Petitioner, Adam Samia at 8. Echelon was a front company for the operations of Paul LeRoux, a South African national who ran a global criminal enterprise. Id.

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