What is the test for admissible hearsay evidence in criminal proceedings?

Our review is for an abuse of discretion and we find none. (People v. Grimes (2016) 1 Cal.5th 698, 711.) The rationale underlying the hearsay exception in Evidence Code section 1230 is as follows: "When hearsay evidence is admitted it is usually because it has a high degree of trustworthiness. [Citations.] . . . [A] person's interest against being criminally implicated gives reasonable assurance of the veracity of his statement made against that interest." (People v. Spriggs (1964) 60 Cal.2d 868, 874.) "To demonstrate that an out-of-court declaration is admissible as a declaration against interest, '[t]he proponent of

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such evidence must show that the declarant is unavailable, that the declaration was against the declarant's penal interest when made and that the declaration was sufficiently reliable to warrant admission despite its hearsay character.' [Citation.] 'In determining whether a statement is truly against interest within the meaning of Evidence Code section 1230, and hence is sufficiently trustworthy to be admissible, the court may take into account not just the words but the circumstances under which they were uttered, the possible motivation of the declarant, and the declarant's relationship to the defendant.' [Citation.]" (People v. Grimes, supra, 1 Cal.5th at p. 711.)