SNOWDEN
v.
STATE OF FLORIDA
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
A codefendant's statement that does not inculpate the defendant and is used purely to provoke the defendant's reaction during custodial interrogation does not violate the Confrontation Clause.
[1] A codefendant's out-of-court statement does not violate the Sixth Amendment Confrontation Clause when the statement is not related to any confession or inculpatory statem…
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“A violation of the Confrontation Clause, as discussed in Bruton, does not occur when the codefendant's statement is 'not related to any confession or inculpatory statement' by the codefendant about the defendant.”
Court's statement of applicable law regarding when Confrontation Clause violations do not occur
Snowden was convicted of first degree murder and attempted first degree murder. During his custodial interrogation, police showed Snowden a codefendan…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Fundamental Error Review cases and more on FLexlaw
FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA
_____________________________
No. 1D2024-0359 _____________________________
AMOS DEHONTIQUAN SNOWDEN, JR.,
Appellant,
v.
STATE OF FLORIDA,
Appellee. _____________________________
On appeal from the Circuit Court for Escambia County. John F. Simon, Jr., Judge.
June 4, 2025
PER CURIAM.
Appellant argues that his convictions and sentences for first degree murder and attempted first degree murder must be reversed, claiming fundamental error in the admission of an outof-court statement from a codefendant. See Bruton v. United States, 391 U.S. 123, 126 (1966) (holding that a Sixth Amendment Confrontation Clause violation occurred when a non-testifying codefendant’s confession was admitted at trial). Because Appellant did not make this argument at trial, this unpreserved claim is subject to fundamental error review. See Jack v. State, 349 So. 3d 925, 927 (Fla. 1st DCA 2022).
2
A violation of the Confrontation Clause, as discussed in Bruton, does not occur when the codefendant’s statement is “not related to any confession or inculpatory statement” by the codefendant about the defendant. Sheppard v. State, 151 So. 3d 1154, 1169 (Fla. 2014). Additionally, the Confrontation Clause is not implicated when “the statements were used purely as a provocation to observe [the defendant’s] reactions.” Jackson v. State, 18 So. 3d 1016, 1032 (Fla. 2009). The codefendant’s statement here that he “drove the car” did not implicate Appellant in any crimes and was shown to Appellant during his custodial interrogation to provoke a reaction.
Accordingly, the Confrontation Clause was not violated by the admission of the codefendant’s statement. Appellant fails to demonstrate any error, much less fundamental error, in the admission of the codefendant’s statement.
AFFIRMED.
ROBERTS, RAY, and BILBREY, JJ., concur.
_____________________________
Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331. _____________________________
Jessica J. Yeary, Public Defender, and Kevin P. Steiger, Assistant Public Defender, Tallahassee, for Appellant.
James Uthmeier, Attorney General, and Amanda Uwaibi, Assistant Attorney General, Tallahassee, for Appellee.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Bruton v. United States, 391 U.S. 123 (U.S. 1968)
- Jackson v. State, 18 So. 3d 1016 (Fla. 2009)