Bruton v. United States, supra; Reeves v. State, supra, p. 3." Reddish v. State, 238 Ga. 136 (1), 138 ( 231 S.E.2d 737). The state argues that since the witness used the word "they" instead of defendant's name there was no Bruton violation, and cites Fortner v. State, 248 Ga. 107 (1) ( 281 S.E.2d 533) in support.
We find no Bruton error. Parker v. Randolph, supra; Casper v. State, 244 Ga. 689 (1) ( 261 S.E.2d 629) (1979).Reddish v. State, 238 Ga. 136 (1) ( 231 S.E.2d 737) (1977), relied on by the defendants, was decided before Parker v. Randolph and is inapposite. Although the trial court properly instructed the jury in that case, the name of the co-defendant was not removed and the statements were contradictory rather than interlocking. In his statement Reddish denied participating in the robbery while his co-defendant's confession showed Reddish as the triggerman.
The trial judge in the case before us did not abuse his discretion in admitting the photograph. Lamb v. State, 241 Ga. 10, 12 ( 243 S.E.2d 59) (1978); Reddish v. State, 238 Ga. 136, 139 ( 231 S.E.2d 737) (1977). III. Sentence Review.
Moreover, the evidence against Boyd was overwhelming and, accordingly, if there had been error, it would have been harmless. Schneble v. Florida, 405 U.S. 427 (1972); Reddish v. State, 238 Ga. 136 ( 231 S.E.2d 737) (1977). 2.
The trial court did not err in admitting these photographs. Godfrey v. State, 243 Ga. 302 (1979); Davis v. State, 240 Ga. 763, 766, 767 ( 243 S.E.2d 12) (1978); Reddish v. State, 238 Ga. 136 ( 231 S.E.2d 737) (1977); Edwards v. State, 233 Ga. 625, 627 ( 212 S.E.2d 802) (1975). 7. Challenge to Jury Array
We affirm. 1. Appellant complains that the trial court erred in allowing a witness to testify, over objection, as to incriminating statements allegedly made to her by appellant, in violation of Bruton v. United States, 391 U.S. 123 ( 88 S.C. 1620, 20 L.Ed.2d 476) (1968) and Reddish v. State, 238 Ga. 136 ( 231 S.E.2d 737) (1977). The testimony objected to is that of Robenna Butts, who repeated a statement made by appellant to her that, "he might have killed a man for $5.00."
Though a statement is inadmissible under Bruton, its admission may be harmless and thus not necessarily reversible error. For example, if the statement is merely cumulative of other competent evidence, its admission is likely not harmful. Since even uncured Bruton violations may under certain circumstances be harmless, a trial court could reasonably conclude under similar circumstances that a curative instruction is all that is necessary to remove the improper statement from the jury's consideration. See, e.g., Borders v. State, 270 Ga. 804, 810-811 (4) (b) ( 514 S.E.2d 14) (1999); Hanifa v. State, 269 Ga. 797, 804 (2) ( 505 S.E.2d 731) (1998); Montijo v. State, 238 Ga. App. 696, 701-702 (3) (b) ( 520 S.E.2d 24) (1999); see generally Reddish v. State, 238 Ga. 136, 138 (1) ( 231 S.E.2d 737) (1977), citing Schneble v. Florida, 405 U.S. 427, 430 ( 92 S.Ct. 1056, 31 L.Ed.2d 340) (1972).Copeland v. State, 266 Ga. 664, 667 (3) (b) ( 469 S.E.2d 672) (1996); Alexander v. State, 236 Ga. App. 142, 145 (1) ( 511 S.E.2d 249) (1999).
]" Where evidence contained in the confession was established by other evidence, its admission in violation of the Bruton rule is considered cumulative and therefore harmless.Reddish v. State, 238 Ga. 136, 138 (1) ( 231 S.E.2d 737)1977).Rachel v. State, 247 Ga. 130, 135 (4) ( 274 S.E.2d 475) (1981).
"[E]vidence of the confession of a co-defendant implicating a defendant cannot be admitted against that defendant at a joint trial where the co-defendant does not take the stand and is not available for cross examination." Reddish v. State, 238 Ga. 136, 138 (1) ( 231 S.E.2d 737) (1977) (citing Bruton, supra). The implication of another defendant must be direct. It is not a Bruton violation if the redacted confession identifies the defendant only through the jury's making connections with other evidence and drawing inferences.
Id., at 129. The confession of one joint offender, made after the enterprise has ended, is admissible only against himself, OCGA § 24-3-52 (Code Ann. § 38-414), and cannot be used against the other defendant at a joint trial where the joint offender does not testify and is not available for cross-examination. Bruton v. United States, 391 U.S. 123 ( 88 SC 1620, 20 L.Ed.2d 476); Reddish v. State, 238 Ga. 136, 138 ( 231 S.E.2d 737) (1977). However, there is no Bruton violation when the testimony presented in the co-defendant's confession is supported by the complaining defendant's own confession.