In Chambers v. Mississippi, 410 U.S. 284 (1973), a state court excluded testimony that a person other than the defendant confessed to the charged murder on three separate occasions, on the grounds that Mississippi did not recognize a hearsay exception for statements against penal interest. (Id. at pp. 298-299.) The United States Supreme Court found that the defendant's federal constitutional rights to a fair trial were violated because "the testimony rejected by the trial court . . . bore persuasive assurances of trustworthiness and thus was well within the basic rationale of the exception for declarations against interest and was critical to Chambers' defense." (Id. at p. 302.) The defendant sought to present testimony that a third party repeatedly had confessed to the crime. Id. at 289. Acknowledging that no hearsay exception under Mississippi law expressly authorized the admission of such out-of-court statements, the Court held that the trial court nonetheless had erred in precluding the evidence. Id. at 302-03. Specifically, it found the defendant's constitutional right to present a defense trumped the state rule when the proffered statements had all the circumstantial hallmarks of reliability underlying traditional exceptions to the general rule precluding hearsay. Id. at 300-02. The application of state evidentiary rules, "under the facts and circumstances of that case," deprived the defendant of a fair trial. (Id. at p. 303.) There, a third person named McDonald had signed a sworn confession and later repudiated it. (Id. at pp. 288-289.) At defendant Chambers' trial, the state court excluded hearsay testimony critical to the defense: testimony that McDonald had orally confessed the murder to three different friends (confessions that were corroborated by other evidence in the case, and that bore persuasive assurances of trustworthiness). This exclusion -- coupled with the state's refusal to permit the defendant to cross-examine McDonald because of a state rule that a party may not impeach his own witness -- denied the defendant a trial "in accord with traditional and fundamental standards of due process." (Id. at p. 302.) The Court stated: Although perhaps no rule of evidence has been more respected or more frequently applied in jury trials than that applicable to the exclusion of hearsay, exceptions tailored to allow the introduction of evidence which in fact is likely to be trustworthy have long existed. The testimony rejected by the trial court here bore persuasive assurances of trustworthiness and thus was well within the basic rationale of the exception for declarations against interest. The hearsay rule must bend when the State has no sufficient basis for doubting the reliability of the hearsay statement and it could have aided the jury in its determination of a material issue. The Supreme Court has stated that Chambers does not stand for the proposition that the defendant is denied a fair opportunity to defend himself whenever a state or federal rule excludes favorable evidence. See United States v. Scheffer, 523 U.S. 303, 316, 140 L. Ed. 2d 413, 118 S. Ct. 1261 (1998). The Supreme Court held that exclusion of defense evidence of a witness's out-of-court confessions under state evidence law as hearsay, combined with the inability of a defendant to cross-examine the prosecution witness regarding his prior confession when the witness had denied complicity on the stand, violated due process by depriving defendant of the right to present a defense. (Id. at pp. 297-298, 302-303.) Among the many distinguishing factors between defendant's case and Chambers, we point out that the Chambers court emphasized the statements excluded under state law "bore persuasive assurances of trustworthiness." (Id. at p. 302.) The Supreme Court overturned a defendant murder conviction because the trial court refused to allow defendant to cross-examine a witness who had three times confessed to the murder, but later repudiated his confession. Although the jury heard that the witness had confessed to the murder and had later repudiated his confessions, the defendant was not allowed to probe the circumstances of the witness's confessions or challenge the witness's renunciation of his confessions. (Chambers, supra, 410 U.S. at pages 291-292.) The defendant was also not allowed to present further exculpatory testimony from three other witnesses who would have testified to the first witness's confessions. (Chambers, supra, 410 U.S. at pages 292-294.) Thus, the Chambers court held that defendant was denied a fair trial. The trial court excluded evidence that a third party had repeatedly confessed to the murder with which the defendant was charged, and the court refused to allow cross-examination of the third party at trial by the defendant. (Chambers at pp. 287-289, 295.) The U.S. Supreme Court concluded that the defendant had been denied a fair trial and reversed, but it strictly limited its decision to the facts of the case before it. (Chambers at pp. 302-303.)