Brief Fact Summary
Williamson's employee, Harris, was stopped by the police with 19 kilograms of cocaine in his car. A DEA agent interviewed Harris after his arrest. Harris told the agent that he was transporting the cocaine for Williamson. Harris freely implicated himself, but did not want his story to be recorded and refused to sign a written version of the statement. Harris refused to testify at trial and the judge admitted Harris's statements pursuant to Federal Rule of Evidence 804(b)(3), as a self-inculpatory statement and exception to the hearsay rule.
Rule of Law and Holding
Federal Rule of Evidence 804(b)(3) "does not allow admission of non-self-inculpatory statements, even if they are made within a broader narrative that is generally self-inculpatory."