In Idaho v. Wright, 497 U.S. 805 (1990), the United States Supreme Court rejected the claim that the child's hearsay statements "are per se unreliable, or at least presumptively unreliable, on the ground that the trial court found the younger daughter incompetent to testify at trial." (Wright, at pp. 824, 825.) It stated that "the Confrontation Clause does not erect a per se rule barring the admission of prior statements of a declarant who is unable to communicate to the jury at the time of trial." (Wright, at pp. 824, 825.) the Supreme Court identified a number of nonexclusive factors that are relevant to the determination of whether child hearsay statements possess the requisite indicia of reliability: (1) spontaneity and consistent repetition of the statement(s); (2) the declarant's mental state; (3) the declarant's use of terminology unexpected of a child of similar age; (4) the lack of a motive to fabricate. (Ibid.) Courts have "considerable leeway in their consideration of appropriate factors." ( Id. at p. 822) The "unifying principle is that these factors relate to whether the child declarant was particularly likely to be telling the truth when the statement was made." (Ibid.) In Idaho v. Wright, the trial court allowed a medical doctor to testify about statements made by a 2 1/2-year-old child regarding sexual abuse. Wright, 497 U.S. at 809-811. The child was too young to testify and was found to be incapable of communicating with the jury. Wright, 497 U.S. at 816. She was thus unavailable within the meaning of the Confrontation Clause. Id. The trial court admitted her statements through the doctor under Idaho's residual hearsay rule, which is identical to MRE 803(24). Wright, 497 U.S. at 812. The Idaho Supreme Court found that the statements made to the doctor had no "particularized guarantees of trustworthiness." Wright, 497 U.S. at 818. The United States Supreme Court agreed. In affirming, it indicated that "particularized guarantees of trustworthiness" must be shown from "the totality of the circumstances." Wright, 497 U.S. at 819. "The relevant circumstances include only those that surround the making of the statement and that render the declarant particularly worthy of belief." Id. The Court discussed the Confrontation Clause: The Confrontation Clause of the Sixth Amendment, made applicable to the States through the Fourteenth Amendment, provides: "In all criminal prosecutions, the accused shall enjoy the right . . . to be confronted with the witnesses against him." From the earliest days of our Confrontation Clause jurisprudence, we have consistently held that the Clause does not necessarily prohibit the admission of hearsay statements against a criminal defendant, even though the admission of such statements might be thought to violate the literal terms of the Clause. The Court reaffirmed only recently that "while a literal interpretation of the Confrontation Clause could bar the use of any out-of-court statements when the declarant is unavailable, this Court has rejected that view as 'unintended and too extreme.'". The Court further stated: The Court noted in Ohio v. Roberts, 448 U.S. 56 (1980) that the Confrontation Clause "operates in two separate ways to restrict the range of admissible hearsay." Ibid. "First, in conformance with the Framers' preference for face-to-face accusation, the Sixth Amendment establishes a rule of necessity. In the usual case . . ., the prosecution must either produce, or demonstrate the unavailability of, the declarant whose statement it wishes to use against the defendant." Ibid. Second, once a witness is shown to be unavailable, "his statement is admissible only if it bears adequate 'indicia of reliability.' Reliability can be inferred without more in a case where the evidence falls within a firmly rooted hearsay exception. In other cases, the evidence must be excluded, at least absent a showing of particularized guarantees of trustworthiness." Wright, supra, p 814. The Supreme Court held that evidence which corroborates the truth of an accomplice's confession is irrelevant to the determination of the confession's reliability. See 497 U.S. at 822 ("To be admissible under the Confrontation Clause, hearsay evidence used to convict a defendant must possess indicia of reliability by virtue of its inherent trustworthiness, not by reference to other evidence at trial."). The use of corroborating evidence to establish a statement's reliability is "no substitute for cross-examination of the declarant at trial" and would allow the admission of presumptively unreliable statements by bootstrapping on the trustworthiness of other evidence admitted at trial. Wright, 497 U.S. at 822-23. However, the Supreme Court in Wright did not reject the use of the interlocking character of codefendant confessions as probative of their reliability, but merely "declined to rely on corroborative physical evidence" in applying Lee's analysis. 497 U.S. at 824. The Supreme Court explained that a decision as to whether a statement bears particular indicia of reliability should not be determined from corroborative evidence. It held that the admissibility of the hearsay statements of an unavailable witness depends upon whether the proponent of the evidence has carried its burden of showing sufficient indicia of reliability. ( Id. at p. 816.) The requisite reliability requirement "could be met in either of two circumstances: where the hearsay statement 'falls within a firmly rooted hearsay exception,' or where it is supported by 'a showing of particularized guarantees of trustworthiness.' " (Ibid.) With regard to the particular contention here, the court said: "The State responds that a finding of 'particularized guarantees of trustworthiness' should instead be based on a consideration of the totality of the circumstances, including not only the circumstances surrounding the making of the statement, but also other evidence at trial that corroborates the truth of the statement. We agree that 'particularized guarantees of trustworthiness' must be shown from the totality of the circumstances, but we think the relevant circumstances include only those that surround the making of the statement and that render the declarant particularly worthy of belief. . . .. . .In other words, if the declarant's truthfulness is so clear from the surrounding circumstances that the test of cross-examination would be of marginal utility, then the hearsay rule does not bar admission of the statement at trial. The basis for the 'excited utterance' exception, for example, is that such statements are given under circumstances that eliminate the possibility of fabrication, coaching, or confabulation, and that therefore the circumstances surrounding the making of the statement provide sufficient assurance that the statement is trustworthy and that cross-examination would be superfluous. " ( Id. at pp. 819-820.) Summarizing its discussion, the court said: "In short, the use of corroborating evidence to support a hearsay statement's 'particularized guarantees of trustworthiness' would permit admission of a presumptively unreliable statement by bootstrapping on the trustworthiness of other evidence at trial, a result we think at odds with the requirement that hearsay evidence admitted under the Confrontation Clause be so trustworthy that cross-examination of the declarant would be of marginal utility." ( Id. at p. 823.) The dissent disagreed with this conclusion. ( Id. at pp. 827-834 (dis. opn. of Kennedy, J.).)