United States Eleventh Circuit

Convictions for offenses committed in carrying out a fraudulent scheme to sell high-yield promissory notes issued by defendants' companies to individual investors, are affirmed in part and vacated in part where: 1) the district court committed a Bruton violation when it permitted the prosecutor to introduce into evidence an out-of-court statement by codefendant that implicated him in most, if not all, of the charged offenses; and 2) the admission of codefendant's affidavit, and the indispensable role it played in the prosecutor's closing argument to the jury, was not harmless beyond a reasonable doubt.

Appellate Information

• Decided 09/05/2008
• Published 09/05/2008

Judges

Court

• United States Eleventh Circuit

Counsel