But, the Court found no such problem in Street’s case, “holding] that the trial judge’s instructions were the appropriate way to limit the jury’s use of [the co-conspirator’s confession] in a manner consistent with the Confrontation Clause.” Id. at 417, 105 S.Ct. 2078. Street is one application of the general, long-standing principle that the potential for jury misuse of evidence can often be curbed by a limiting instruction. Indeed, whenever the Supreme Court has permitted a jury to consider evidence that has the potential to be misused, e.g., to be considered in a way that would violate the defendant’s constitutional rights, it has required that a proper jury instruction be given to avoid the misuse. See, e.g., Harris v. New York, 401 U.S. 222, 226, 91 S.Ct. 643, 28 L.Ed.2d 1 (1971) (<HOLDING>); Spencer v. Texas, 385 U.S. 554, 559-61, 87
holding that statements elicited from a defendant in violation of his miranda rights could be introduced to impeach that defendants credibility when the jury was instructed that the statements were not to be considered as evidence of his guilt holding that evidence of a defendants prior criminal convictions could be introduced for the purpose of sentence enhancement if the jury was instructed that the evidence could not be used for the purposes of determining guilt holding that the admission of unlawfully seized evidence of a crime was admissible if the jury was instructed that the evidence could be considered only in assessing a defendants credibility and not for determining guilt holding that admission of statements obtained in violation of miranda was harmless beyond a reasonable doubt where the substance of the statements was introduced through other untainted testimony holding that where a defendant expressly manifested his belief in the truth of the statements contained in the motion to dismiss thereby adopting those statements as his own such statements are admissible against the defendant in the states case in chief