In People v. Blankenship (1985) 167 Cal. App. 3d 840, the defendant claimed another man, Gary Hahn, had committed the crime in question. Mr. Hahn invoked the privilege against self-incrimination. Defense counsel then made an offer of proof that the defendant would testify Mr. Hahn admitted committing the charged offense. Defense counsel sought to introduce Mr. Hahn's statement, through the defendant's testimony, as a declaration against penal interest. In other words, the ruling at issue in Blankenship involved a declaration against penal interest. The trial court ruled the statement inadmissible because there was insufficient proof of trustworthiness ( id. at p. 848), a proper consideration under Evidence Code section 1230. The Blankenship opinion is unclear as to whether the trial court purported to rule under Evidence Code section 352. The Court of Appeal affirmed the judgment. But in doing so, it confused the issues. The Blankenship court stated: "In the present case, nothing in the offer of proof concerning defendant's proposed testimony provided an internal indication of veracity. As the proposed testimony was to come from defendant himself it was highly suspect both because defendant had a motive to falsify and because accurate details concerning the crime could be explained by defendant's own knowledge and guilt rather than Hahn's." ( People v. Blankenship, supra, 167 Cal. App. 3d at p. 849.)