Stephen v. United States District Court

How later courts describe this case

• finding severance not required where defendants did not present mutually antagonistic defenses and State did not introduce incriminating statement by non-testifying co-defendant
• discussing difference for purposes of harmless error analysis between structural and mere trial errors
• no Faretta inquiry required in the absence of an explicit assertion of the right to self-representation
• state’s failure to object to the petitioner’s claim on procedural grounds waived procedural default objection
• co-conspirator tried as co-defendant and third party, recruited by defendants to join in murder scheme, testified against both