California, United States of America
The following excerpt is from People v. Ramos, D074429 (Cal. App. 2020):
The trial court correctly ruled that these statements "could subject Elias to criminal liability for participation in a criminal street gang under [section] 186.22 [subdivision] (a)." " 'To be against penal interest . . . the statement need not be made to persons who are likely to use it against the declarant in court proceedings. Declarations against penal interest are received notwithstanding that they were spoken in confidence in the expectation they would not be repeated to the authorities. [Citations.] Indeed, that makes such declarations more trustworthy.' " (People v. Masters (2016) 62 Cal.4th 1019, 1056.) Moreover, the songs not only helped establish
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