In People v. Arauz (2012) 210 Cal.App.4th 1394, a jailhouse conversation between defendant and his cellmate was secretly recorded. Defendant's statements, which were self-inculpatory and inculpatory of a codefendant, were admitted at a joint trial as declarations against interest. In affirming that ruling, the appellate court found the statements were specifically disserving of the declarant's penal interests and, because they were not testimonial, they were not subject to the Confrontation Clause. (Id. at p. 1397.)