U.S. v. Magana-Olvera, No. 88-3280 (9th Cir.) (917 F.2d 401) (October 23, 1990) (Judge Cynthia Holcomb Hall)
Here the Court held that the "against interest" requirement of Rule 804(b)(3) applies not only to confessions of criminal responsibility, but also to remarks that "tend to subject" the declarant to criminal liability. However, it also stated that "each statement must (1) "solidly inculpat[e]" the declarant and (2) "be one …
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