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2 rather than the Confrontation Clause. On top of that, the two federal cases do not discuss the effectiveness of limiting instructions, much less any need for redaction. Sparf v. United States holds that the co-conspirator exception to the hearsay rule does not apply to statements made after the conspiracy has ended. 156 U. S. 51, 56 (1895). Emphasizing the trial court’s error in admitting the statements against both defendants, the Court explained that the trial court should have admitted them against the speaker and excluded them against his codefendant. Id., at 58. Neither limiting instructions nor redaction came up. United States v. Ball is similarly tangential to Samia’s case. 163 U. S. 662 (1896). There, the Court held that the trial court had not abused its discretion in trying three codefendants together. Id., at 672. As support for that point, the Court noted that when the Government introduced the admissions of one defendant, “the [trial] court at once said, in the presence of the jury, that, of course, it would be only evidence against him, if he said anything; and the court was not afterwards requested to make any further ruling upon this point.” Ibid. The Court assumed in passing that the limiting instruction was effective—but the codefendants did not argue otherwise, and they did not ask the court to alter the statements.

The two state cases at least address (and endorse) the use of a limiting instruction after the admission of a codefendant’s confession. State v. Workman 15 S. C. 540, 545 (1881); Jones v. Commonwealth, 72 Va. 836, 839–840 (1878). One even holds that a trial court should not alter a statement by redacting a codefendant’s name. Workman, 15 S. C., at 545. Like the federal cases, though, the state cases make no mention of the confrontation right. Same for the treatises cited by the Court. See S. Phillipps, Law of Evidence *82–*83 (1816); 3 J. Wigmore, Evidence §2100, p. 2841, and n. 5 (1904). So for all we know, the cases cited by the Court and the treatises proceed from the premise that an ordinary