This section contains the nature of the case and procedural background.

Randolph (D) and four codefendants committed an armed robbery on Douglas (the victim) by using a poker game as a backdrop. While the game was going on, Douglas became nervous and attempted to arm himself. He was shot and killed. Each of the five defendants confessed to the details of the situation at a later date. These confessions corroborated each other, combining to form a complete account of the event. Each confession was introduced only against the defendant making the confession. However, since all five of them were tried jointly, and the written confessions were introduced without any defendant testifying, the jury was able to apply different confessions to different defendants without the confessions being tested by cross-examination. D appealed, claiming he was refused the ability to cross-examine the other defendants about their confessions.

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