The People v. John Stone, 29 N.Y.3d 166

Background

Defendant John Stone was tried for stabbing the victim; the victim identified Stone at trial as the attacker and testified about a post-attack statement directed at the victim's partner.
The victim's estranged wife (a potential eyewitness) initially identified defendant to police but later told the prosecutor she did not see the attack and did not want to testify; she could not be located at trial.
The People called a detective who testified he interviewed the wife and then ran computer checks on a person identified as a suspect; defense objected that this implied the wife had identified Stone and was deprived of confrontation.
The trial court struck the detective's testimony about speaking to the wife and the computer checks, denied a mistrial, and instructed the jury multiple times to disregard the stricken testimony; the court also instructed the jury the wife was unavailable.
Jury convicted Stone of first-degree assault (acquitted of second-degree attempted murder); post-verdict defendant moved under CPL 330.30 alleging juror misconduct, which the court denied without a hearing; Appellate Division affirmed and leave to appeal to Court of Appeals was granted.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether detective's testimony about interviewing the wife violated Confrontation Clause	Prosecution: testimony was permissible/context did not violate confrontation because not powerfully incriminating and other inferences existed	Stone: testimony implied the wife identified him as assailant, depriving him of right to confront her; requested mistrial	Court: No violation; any prejudice cured by striking testimony and curative instructions; error harmless beyond a reasonable doubt
Whether stricken testimony was "powerfully incriminating" such that instructions could not cure prejudice	Prosecution: context showed alternative inference (victim had identified defendant earlier); testimony not equivalent to co-defendant admission	Stone: wife's potential identification was highly prejudicial and akin to Bruton-type evidence that jurors cannot ignore	Court: Not powerfully incriminating given context; jurors could infer suspect status from victim's statements; instructions were adequate
Whether Bruton v. United States applies to a nontestifying spouse's implied statement	Prosecution: Bruton inapplicable; spouse is not a codefendant and had no stake like a codefendant	Stone: spousal identification functionally equated to an incriminating non-testifying statement that jurors can't ignore	Court: Bruton not applicable; spouse not similarly situated to codefendant; redaction and instructions suffice if needed
Whether defendant was entitled to a hearing on CPL 330.30 juror-misconduct motion	Prosecution: court properly denied without hearing based on record and law	Stone: alleged post-verdict juror interaction with victim warranted a hearing	Court: No hearing required; denial without hearing was proper

Key Cases Cited

Crawford v. Washington, 541 U.S. 36 (testimonial hearsay triggers Confrontation Clause analysis)
People v. Eastman, 85 N.Y.2d 265 (New York confrontation-right principles)
People v. Pealer, 20 N.Y.3d 447 (testimonial statements and confrontation analysis)
People v. Crimmins, 36 N.Y.2d 230 (harmless error standard for constitutional violations)
Chapman v. California, 386 U.S. 18 (harmless beyond a reasonable doubt standard for constitutional error)
People v. Baker, 14 N.Y.3d 266 (jurors presumed to follow curative instructions)
People v. Cedeno, 27 N.Y.3d 110 (when curative instructions/redaction can cure prejudicial statements; Bruton discussion)
Gray v. Maryland, 523 U.S. 185 (context matters for powerfully incriminating statements)
Richardson v. Marsh, 481 U.S. 200 (limitations on Bruton and role of limiting instructions)
Bruton v. United States, 391 U.S. 123 (statements of non-testifying codefendant and prejudice)
People v. Samandarov, 13 N.Y.3d 433 (standards for CPL 330.30/330.40 postverdict proceedings)