In July, Barry Kamins wrote a thoughtful article for the Law Journal in which he suggested that the U.S. Supreme Court’s decision last term in Samia v. United States, 599 U.S. ___ (2023), sounded the death knell for Bruton v. United States, 391 U.S. 123 (1968), a landmark Warren court precedent. As a follow-up, it seems worthwhile to ask how lower courts would likely resolve a series of hypothetical cases after Samia.

I.