Commonwealth v. Cannon, 22 A.3d 210

Joint trial of Khalif Alston and Ernest Cannon for murder, robbery, conspiracy, and weapons offense.
Alston testified via redacted confession that referred to Cannon as 'the other guy'; redaction used neutral terms.
Prosecutor opened by summarizing Alston's statement with redaction, then described Alston's confession.
Appellee Cannon objected to the redaction being 'broken' by the prosecutor's remarks; mistrial motion denied.
Trial court gave immediate cautionary instructions reiterating that opening statements are not evidence and that Alston's statement was admissible only against Alston.
Superior Court remanded for new trial, finding Bruton-type prejudice; Pennsylvania Supreme Court granted review to address Bruton extension in presence of prosecutor commentary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prosecutor’s opening comment violated Bruton despite redaction.	Cannon argues Bruton extension; redaction negated; prejudice to Cannon.	Commonwealth argues proper redaction and cautionary instructions cured any prejudice.	Not Bruton violation; redaction plus cautionary instructions sufficient; no new trial required.

Bruton v. United States, 391 U.S. 123 (1968) (co-defendant confession directly implicating defendant requires stronger protection than limiting instructions)
Richardson v. Marsh, 481 U.S. 200 (1987) (redacted co-defendant confession admissible with limiting instruction when no direct implication)
Gray v. Maryland, 523 U.S. 185 (1998) (redaction and contextual implication considerations; dangers of inferential incrimination)
Brown, 925 A.2d 147 (Pa. 2007) (prospect of Bruton extension to counsel comments; cautionary instruction may cure prejudice)
Commonwealth v. Travers, 768 A.2d 845 (Pa. 2001) (permits redacting 'the guy' for co-defendant statements in joint trials)