Brief Fact Summary
The defendant's co-conspirator (Mr. Tilley) in a stamp theft operation had an alleged conversation with one Mr. Melvin, stating that "Bucky [Barret]" / defendant was not involved in the stamp theft. Mr. Tilley died and was therefore unavailable. The defense contended that Tilley's statements were admissible as exceptions to the hearsay rule under the theory that they were against Tilley's self-interest as they tended to make more probable his complicity in the stamp theft crime.

Rule of Law and Holding
In criminal cases, where testimony is offered tending to exculpate the accused and inculpate the out-of-court declarant, there must be independent corroboration of the testimony's trustworthiness.

Topics
The Hearsay Rule

Subtopics
Declarations Against Interest