Did ''Antagonistic'' Defenses of Co-Defendants Make An Unfair Trial ?

In McCray v. State, 416 So. 2d 804 (Fla. 1982), the court concluded that in a trial in which appellant McCray asserted that his right to a fair trial was violated "because the defenses of his codefendants . . . were completely antagonistic to his defense," id. at 806, the joint trial of McCray and his codefendants "did not in any way prejudice the right of McCray to a fair determination of his guilt or innocence of the offense of first-degree murder." Id. at 807. The court noted in McCray that the appellant had a full opportunity to cross- examine all witnesses brought against him, and that the evidence was not so complex that the jury could not understand the case, apply the evidence, and make individualized determinations of guilt regarding each defendant. See id. at 806-07.