California, United States of America
The following excerpt is from People v. Howard, A139179 (Cal. App. 2015):
[and] that the declaration was against the declarant's penal interest when made,' " the party seeking to admit such evidence must show " 'that the declaration [is] sufficiently reliable to warrant admission despite its hearsay character.' " (People v. Brown (2003) 31 Cal.4th 518, 535.)
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