In Lee v. Illinois, 476 U.S. 530, 540, 106 S. Ct. 2056, 2062, 90 L. Ed. 2d 514 (1986), the Supreme Court stated that the category of "declarations against penal interest" is "too large a class for meaningful Confrontation Clause analysis" and held that "a confession by an accomplice which incriminates a criminal defendant" should be considered a distinct category of hearsay for the purpose of determining its admissibility under the Sixth Amendment. See id. the United States Supreme Court has expressly refused to analyze "a confession by an accomplice which incriminates a criminal defendant" as a declaration against penal interest for the purpose of determining the admissibility of such hearsay under the Confrontation Clause, see Lee, 476 U.S. at 544 n.5, 106 S. Ct. at 2064 n.5. The Court stated in Lee that, unlike hearsay statements that fall under firmly rooted hearsay exceptions, which presumably include statements against penal interest made in other contexts, accomplices' confessions that incriminate defendants are "presumptively unreliable" under the Sixth Amendment's Confrontation Clause. Lee, 476 U.S. at 541, 106 S. Ct. at 2062. The Court recognized that whether the portions of an accomplice's confession regarding a defendant's participation in a crime are sufficiently trustworthy to be admissible without cross-examination under the Sixth Amendment is determined by considering: (1) the circumstances surrounding the accomplice's confession and; (2) in a case in which the defendant also made a confession, the extent to which the accomplice's and the defendant's confessions "interlock." See Lee, 476 U.S. at 544-46, 106 S. Ct. at 2064-65;