What is the hearsay rule for declarations against penal interest?

the hearsay rule for declarations against penal interest provides, in relevant part: "Evidence of a statement by a declarant having sufficient knowledge of the subject is not made inadmissible by the hearsay rule if the declarant is unavailable as a witness and the statement, when made, . . . so far subjected him to the risk of . . . criminal liability . . . that a reasonable man in his position would not have made the statement unless he believed it to be true." (Evid. Code, 1230.) "[T]he rationale underlying the exception is that 'a person's interest against being criminally implicated gives reasonable assurance of the veracity of his statement made against that interest,' thereby mitigating the dangers usually associated with the admission of out-of-court statements." (People v. Grimes (2016) 1 Cal.5th 698, 711 (Grimes).)

To establish admissibility under this exception, the proponent has the burden of showing: (1) the declarant is unavailable, (2) the declaration was against the declarant's penal interest when made, and (3) the declaration was sufficiently reliable to warrant admission despite its hearsay character. (Grimes, supra, 1 Cal.5th at p. 711; People v. Duarte (2000) 24 Cal.4th 603, 610-611 (Duarte).) "We review a trial court's decision whether a statement is admissible under Evidence Code section 1230 for abuse of discretion." (Grimes, supra, at p. 711.)