The Confrontation Clause's fundamental role is in protecting the right of cross-examination.
At his trial for murder in a Tennessee state court, the defendant testified that the confession he made to the sheriff, and relied upon by the state, was coercively derived from a written confession that an accomplice had previously given the sheriff. The defendant claimed that the sheriff read from the accomplice's confession and directed him to say the same thing in his own confession. In rebuttal, the state called the sheriff who denied that the defendant was read the accomplice's confession or pressured to repeat the terms of that confession. To corroborate this testimony, and to rebut the defendant's claim that his own confession was a coerced imitation, the sheriff read the accomplice's confession to the jury, after the trial judge had twice informed the jury that it was admitted not for the purpose of proving its truthfulness, but for the purpose of rebuttal only. Following such reading, the prosecutor elicited from the sheriff testimony emphasizing the differences between the confessions. The defendant was found guilty and sentenced to life imprisonment. The Tennessee Court of Criminal Appeals reversed, ruling that the introduction of the accomplice's confession denied the defendant his Sixth Amendment right to confront witnesses (674 SW2d 741). On certiorari, the United States Supreme Court reversed.
Were respondent's rights under the Confrontation Clause of the Sixth Amendment violated by the introduction of the accomplice's confession for rebuttal purposes?
The defendant's rights under the confrontation clause of the Sixth Amendment were not violated by the introduction of the confession of the accomplice for the nonhearsay purpose of rebutting defendant's testimony that his own confession was coercively derived from the accomplice's statement, and that the trial judge's instructions were the appropriate way to limit the jury's use of that evidence in a manner consistent with the confrontation clause.