South Carolina v. McDonald
Annotate this CasePetitioner Derrick McDonald and two codefendants were convicted of murder and first-degree burglary. The court of appeals affirmed, rejecting McDonald's argument that his Confrontation Clause rights were violated when the trial court admitted the redacted confession of one of his nontestifying codefendants. No defendant testified at trial. The jury found Defendants guilty of both charges. McDonald appealed, arguing that given the context, Cannon's written confession clearly implicated McDonald in the crimes. The court of appeals affirmed, "find[ing] that the neutral phrase 'another person' inserted into Cannon's statement avoided any [Confrontation Clause] violation." Cannon's confession was redacted using the phrase "another person." The Supreme Court found, after review of the trial court record, that even a casual reading of the confession made it apparent that the confession describes the actions of Cannon and two other male individuals. The Court rejected the State's invitation to find no Confrontation Clause violation based on the trial court's limiting instruction. Despite this finding, the Supreme Court concluded that in light of the overwhelming evidence of guilt, the error in this case was harmless beyond a reasonable doubt. The Court therefore affirmed the court of appeals as modified.
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