Samia v. United States

143 S. Ct. 2004 (2023)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

D traveled to the Philippines to work for crime lord Paul LeRoux. LeRoux tasked D, Joseph Hunter, and Carl Stillwell with killing Catherine Lee, a local real estate broker who LeRoux believed had stolen money from him. Lee was found dead shortly thereafter, shot twice in the face at close range. LeRoux was arrested and became a cooperating witness. Hunter, d, and Stillwell were arrested thereafter. During a search of D’s home, law enforcement found a camera containing surveillance photographs of Lee’s home as well as a key to the van in which Lee had been murdered. Law enforcement found a cell phone containing thumbnail images of Lee’s dead body. Stillwell waived his rights under Miranda and gave a confession. Stillwell admitted that he had been in the van when Lee was killed, but he claimed that he was only the driver and that D had shot Lee. D and Stillwell were each charged with conspiracy to commit murder-for-hire along with other crimes. The Government (P) tried all the men jointly. Hunter and Stillwell admitted that they had participated in the murder. D maintained his innocence. P moved in limine to admit Stillwell’s confession. P proposed that an agent testify as to the content of Stillwell’s confession in a way that eliminated D’s name while avoiding any obvious indications of redaction. The District Court granted P’s motion. P claimed that Hunter had hired D and Stillwell to pose as real-estate buyers and visit properties with Lee. P presented testimony about Stillwell’s confession through DEA Agent Eric Stouch. Stouch recounted the key portion of Stillwell’s confession implicating D. Stouch referred to D as 'the other person' to refer to someone with whom Stillwell had traveled and lived and who carried a particular firearm. The District Court instructed the jury that his testimony was admissible only as to Stillwell and should not be considered as to D or Hunter. The District Court later provided a similar limiting instruction before the jury began its deliberations. D was convicted on all counts. The District Court denied D’s post-trial motions. The District Court then sentenced D to life plus 10 years’ imprisonment. On appeal, D argued that the admission of Stillwell’s confession-even as altered and with a limiting instruction-was constitutional error because other evidence and statements at trial enabled the jury to immediately infer that the “other person” described in the confession was D himself. During opening statements, P asserted that Stillwell drove the van while D “was in the passenger seat,” and that d pulled out a gun, “turned around, aimed carefully, and shot [Lee].” “Stillwell admitted to driving the car while the man he was with turned around and shot [Lee].” D made a laundry list of evidence that P tied to D such that when the confession was presented to the court the jury could do nothing but think that D was 'the other man.' D argued that those statements would allow the jury to infer that he was the “other person” in Stillwell’s confession. The Second Circuit affirmed and D appealed.