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10-1433 U.S. v. Spagnola

Criminal Procedure Severance A co-conspirator’s statement to police that “oh, then, you have me on conspiracy,” does not require severance of the trials. “A Bruton violation occurs only if the confession of a non-testifying co-defendant facially incriminates the non-confessing co-defendant. See, e.g., United States v. Brooks, 125 F.3d 484, 501 (7th Cir. 1997). George’s statement neither facially incriminates ...

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