Henry Adamson v. Ronald Cathel
2011 U.S. App. LEXIS 3819
| 3rd Cir. | 2011Background
- Adamson, a New Jersey prisoner convicted in 1998 for robbery-related offenses, challenged a habeas denial arguing that admitting accomplice statements during cross-examination violated the Confrontation Clause; no limiting instruction on those statements was given to the jury.
- Accomplice Napier and Aljamaar gave statements implicating Adamson; Adamson admitted to reading and signing his own statement after Miranda waiver.
- At trial, the prosecutor cross-examined Adamson using the accomplice statements to highlight differences with Adamson's confession, without limiting instruction.
- The jury was instructed only after closing arguments and received no instruction limiting the accomplice statements to impeachment.
- Appellate Division upheld admission under Street, finding no plain error due to lack of objection and noting non-limiting use did not prejudice Adamson.
- District Court denied habeas relief, and the Third Circuit granted a certificate on the Confrontation Clause issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether failure to give a limiting instruction violated Street | Adamson | Adamson | Yes, contrary to Street |
| Whether the error was harmless or prejudice to the verdict | Adamson | State | Not harmless; substantial and injurious effect on verdict |
Key Cases Cited
- Street v. United States, 471 U.S. 209 (U.S. 1985) (limiting instruction required for impeachment use of co-conspirator statements)
- Bruton v. United States, 391 U.S. 123 (U.S. 1968) (co-defendant confession implicating defendant violates Confrontation Clause)
- Richardson v. Marsh, 481 U.S. 200 (U.S. 1987) (redacted confessions may be admissible with limiting instructions)
- Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (AEDPA clearly established standards for habeas review)
- Brecht v. Abrahamson, 507 U.S. 619 (U.S. 1993) (harmless-error standard for habeas review)