United States v. Coonce All filings pertaining to Wesley Coonce's 2255 in this matter need to be filed in case number, 6:10-cr-03029

Joint capital case in which Hall and Coonce face murder-related charges; motions for severance filed; Bruton redactions proposed for co-defendant statements; court must balance prejudice against judicial economy and assess if redactions render statements admissible.
Court notes preference for joint trials in co-defendant cases and allows severance only when prejudice cannot be mitigated by redactions or other measures.
Court reviews each defendant’s statements and proposed Bruton redactions, concluding most can be redacted to avoid Confrontation Clause violations.
Court determines there is no need for pre-trial severance; recognizes ongoing duty to grant severance if prejudice becomes apparent during trial.
Court grants both severance motions to deny them, but discusses potential sequential penalty phases; ultimately denies severance as untimely and Bruton issues addressed through redactions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether severance is required given Bruton-type prejudice	Hall and Coonce argue joint trial prejudicial	Hall and Coonce argue deprivation of cross-examination	No severance required; redactions sufficient
Whether Bruton redactions address co-defendant statements without violating Confrontation Clause	Government argues redactions render statements non-improper	Defendants argue redacted references still implicate them	Bruton-compliant redactions sufficient for most statements; some statements deemed inadmissible or unnecessary to redact in specific contexts
Whether pre-trial severance should be granted in a capital conspiracy case with only two defendants	Government efficiency favors joint trial	Severance necessary to avoid prejudice	Pre-trial severance denied; potential prejudice mitigated by redactions and trial plan
Whether the court should implement sequential penalty phases as alternative relief	Not identified	Alternative relief requested	Sequential penalty phases considered but not adopted at this time

Bruton v. United States, 391 U.S. 123 (1968) (Confrontation Clause prohibits use of non-testifying co-defendant’s statements in joint trial when incriminating on its face; redactions possible)
Richardson v. Marsh, 481 U.S. 200 (1987) (Redacted statements may be admissible if not incriminating on their face; linkage evidence required)
Zafiro v. United States, 506 U.S. 534 (1993) (Preference for joint trials; severance only for prejudice that cannot be cured by careful trial management)