Does the confrontation clause apply to a statement that is a "firmly rooted" exception to the hearsay rule?

1 We have found one case from this circuit which in dictum suggests that "statements which fall into 'firmly rooted' exception to the hearsay rule presumptively possess sufficient indicia of reliability so as to satisfy the confrontation clause." United States v. Bernal, 719 F.2d 1475 at 1479 (9th Cir.1983). Before making this observation, however, the panel noted "Bernal does not seem to challenge admissibility of that statement on appeal, and so may have waived any confrontation clause objections." 719 F.2d at 2479.