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United States v. Yates | 553 F.2d 518 (1977)
Generally, trial court judges have the authority to comment on and sum up the evidence presented to the jury. But what if the judge’s comments indicate to the jury that the judge believes the elements of a party’s case have been proven? The United States Court of Appeals for the Sixth Circuit considered this question in United States versus Yates.
On January fifth, nineteen seventy six, an individual robbed the Ohio State Bank in Columbus, Ohio. The bank teller identified Michael Yates as the person who committed the robbery.
The next morning, Yates voluntarily agreed to go to the F B I’s office and was interviewed by two agents. After being read his rights and signing a waiver form, Yates confessed to the robbery. The agents then put Yates’s confession into writing, and Yates read and signed it.
Subsequently, Yates was charged in the United States District Court for the Southern District of Ohio with bank robbery. At trial, the government called one of the F B I agents to testify as to the interview with Yates and his written confession. At the end of the agent’s testimony, the prosecutor offered Yates’s confession into evidence, which the court admitted.
After the evidence was admitted, the prosecutor requested that the statement be read in open court. Yates’s attorney responded that the statement didn’t need to be read in open court because it was in evidence and the jury would have time to look at it.
The trial judge agreed, as did the federal prosecutor, that Yates’s statement didn’t need to be read in open court. However, the judge proceeded to state in front of the jury that it was clear from testimony presented at trial that Yates did admit to his participation in the bank robbery.
Yates later took the stand and denied committing the robbery. He testified that he thought he was under investigation for writing bad checks. Further, he testified that he didn’t read the written confession before signing it and that he only signed the statement to cooperate with the F B I.
Following trial, Yates was convicted of bank robbery. He appealed to the Sixth Circuit.
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