In Richardson v. Marsh (1987) 481 U.S. 200, three people (Marsh, Williams, and Martin) participated in a robbery and murders. (Richardson, supra, 481 U.S. 200.) Marsh and Williams were jointly tried for the crimes. Williams did not testify, but his prior statement that he and Martin, while in a car en route to the victims' home, discussed robbing and killing the victims was admitted. (Id. at p. 203.) All references to Marsh's presence in the backseat of the car were omitted. Marsh, however, testified and admitted she was in the car during the discussion but denied hearing it because of the loud music playing. (Id. at p. 204.) Marsh and Williams were jointly tried for, among others, murder. Williams's confession was admitted at trial, but it was redacted to omit all references to Marsh; in fact, it was redacted to omit any indication that anyone other than Williams and a third suspect had participated in the crimes. (Id. at pp. 203-204.) When the confession was admitted, the jury was admonished not to use it against Marsh. Marsh testified, and her testimony placed her at the scene of the crime, although she denied knowing anyone would be robbed or harmed. The central issue was whether Defendant Marsh had known before events unfolded that the victims were to be robbed and perhaps killed. She claimed she had not known, but her co-defendant, Williams, had confessed that he and a third defendant had discussed the plan in front of Marsh while driving to the victims' house. Defendant Williams' confession was admitted against Marsh at their joint trial. 481 U.S. at 203. Williams' statement was redacted to omit all references to Marsh and was linked to her only through other evidence admitted at trial, including her admission that she was present at the scene and participated in certain aspects of the crime. Id. at 203-04. The trial court admonished the jury to consider the confession only against Williams and not to use it against Marsh. Id. at 205. In Richardson, 481 U.S. at 200, the Court declined to extend the Bruton rule to circumstances in which a confession by a non- testifying co-defendant was redacted to omit any reference to the defendant, but other evidence admitted at trial linked the defendant to the confession. Id. at 211. The Court limited Bruton v. United States, 391 U.S. 123 (1968), holding that it created only a "narrow exception" to the "almost invariable assumption of the law that jurors follow their instructions." Id. at 206-07 (citing Francis v. Franklin, 471 U.S. 307, 325 n.9, 85 L. Ed. 2d 344, 105 S. Ct. 1965 (1985)). The Court recognized that the statement incriminated Marsh, id. at 208 n.3, yet it ruled that the admission of the testimony did not violate the Bruton rule because the confession did not name her and became incriminating only after she was linked to the crimes. The statement at issue "was not incriminating on its face, and became so only when linked with evidence introduced later at trial." (Ibid.) The court believed this distinction was critical, and set forth the following rule, "Where the necessity of such linkage is involved, it is a less valid generalization that the jury will not likely obey the instruction to disregard the evidence. Specific testimony that 'the defendant helped me commit the crime' is more vivid than inferential incrimination, and hence more difficult to thrust out of mind. Moreover, with regard to such an explicit statement the only issue is, plain and simply, whether the jury can possibly be expected to forget it in assessing the defendant's guilt; whereas with regard to inferential incrimination the judge's instruction may well be successful in dissuading the jury from entering onto the path of inference in the first place, so that there is no incrimination to forget. In short, while it may not always be simple for the members of a jury to obey the instruction that they disregard an incriminating inference, there does not exist the overwhelming probability of their inability to do so that is the foundation of Bruton's exception to the general rule." (Ibid.) The United States Supreme Court held that the admission of Williams's confession did not violate Bruton v. United States. It reasoned that a confession not incriminating on its face and that becomes so only when linked with evidence introduced at trial does not violate a defendant's confrontation rights. (Id. at p. 208.) "Where the necessity of such linkage is involved, it is a less valid generalization that the jury will not likely obey the instruction to disregard the evidence. Specific testimony that 'the defendant helped me commit the crime' is more vivid than inferential incrimination, and hence more difficult to thrust out of mind." (Ibid.) Thus, the Confrontation Clause is not violated by admission of a confession redacted to eliminate not only the defendant's name but any reference to his or her existence. (Id. at p. 211.) The California Supreme Court held that "the Confrontation Clause is not violated by the admission of a nontestifying codefendant's confession with a proper limiting instruction when . . . the confession is redacted to eliminate not only the defendant's name, but any reference to his or her existence." (Richardson v. Marsh, supra, at p. 211, ) The court distinguished the redacted confession from the confession at issue in Bruton because the redacted confession was not incriminating on its face, but only when linked to other evidence. (Id. at p. 208.) In Richardson v. Marsh, the confession at issue was "redacted to omit all reference to the defendant -- indeed, to omit all indication that anyone other than the codefendant and a named person other than said defendant participated in the crime." (Richardson, supra, 481 U.S. at p. 203.) The high court held that "the Confrontation Clause is not violated by the admission of a nontestifying codefendant's confession with a proper limiting instruction when, as here, the confession is redacted to eliminate not only the defendant's name, but any reference to his or her existence." (Richardson, supra, 481 U.S. at p. 211.) The Supreme Court limited Bruton. The Richardson court held that, "the Confrontation Clause is not violated by the admission of a nontestifying codefendant's confession with a proper limiting instruction when, as here, the confession is redacted to eliminate not only the other defendant's name, but any reference to his or her existence." ut the Richardson court expressed "no opinion on the admissibility of a confession in which the defendant's name has been replaced with a symbol or neutral pronoun." (Richardson, supra, 481 U.S. at page 211, footnote 5.) The Richardson court did, however, reject the "contextual implication" doctrine, which had developed in the federal circuit courts following Bruton. This doctrine holds that a statement that is not "facially incriminating," that does not implicate the defendant by name, nevertheless violates the confrontation clause if the jury may link the codefendant to the statement by other evidence introduced at trial. In Richardson, a nontestifying defendant's confession was redacted to eliminate all references to a codefendant's existence. But in view of other evidence introduced at trial, specifically the codefendant's own testimony, the confession implicated the codefendant in the commission of the crimes. (Richardson, supra, 481 U.S. at pages 203-205.) The Richardson court reasoned that if a nontestifying codefendant's confession becomes incriminating only when linked with other evidence, there is no "overwhelming probability" that the jury will disregard a limiting instruction. Thus, under Richardson, only facially incriminating statements violate the confrontation clause; statements that are incriminating only by connection to other evidence do not. (Richardson, supra, 481 U.S. at pages 208-209.) The Richardson court observed that it was "not possible" to extend the Bruton rule to statements that are incriminating only by connection to other evidence. The Richardson court reasoned that posttrial assessments of whether a nontestifying codefendant's confession was, in light of all of the evidence, so "powerfully incriminating" that a new, separate trial should be ordered for the defendant, "obviously lends itself to manipulation by the defense--and even without manipulation will result in numerous mistrial and appeals." The Richardson court further observed that pretrial hearings to assess a confession's compliance with Bruton, in light of all of the evidence to be introduced, would be "time consuming and obviously far from foolproof." (Richardson, supra, 481 U.S. at page 209.) In sum, Marsh, Williams, and Martin were charged with murder and other offenses. Marsh and Williams were jointly tried; over Marsh's objection, the prosecutor introduced Williams's confession, which was redacted to omit not only any reference to Marsh, but all indication that anyone other than Williams and Martin were involved. (Id. at pp. 202-203.) In addressing Marsh's claim of Bruton error, the United States Supreme Court stated: "There is an important distinction between this case and Bruton, which causes it to fall outside the narrow exception we have created. In Bruton, the codefendant's confession 'expressly implicated' the defendant as his accomplice. Thus, at the time that confession was introduced there was not the slightest doubt that it would prove 'powerfully incriminating.' By contrast, in this case the confession was not incriminating on its face, and became so only when linked with evidence introduced later at trial (Marsh's own testimony)." (Richardson, supra, at p. 208.) The court held: "The Confrontation Clause is not violated by the admission of a nontestifying codefendant's confession with a proper limiting instruction when, as here, the confession is redacted to eliminate not only the defendant's name, but any reference to his or her existence." (Richardson, supra, at p. 211.)