In People v. Chapman (1975) 50 Cal. App. 3d 872, The defendant was convicted of second-degree murder. At trial, the defendant had sought to introduce hearsay declarations by an accomplice, Napoleon Banks. Mr. Banks had stated to other persons that he was the one who shot the victim, while defendant had been attempting to break up the fight. Mr. Banks had invoked the privilege against self-incrimination. Three witnesses testified at a hearing out of the jury's presence that Mr. Banks had said he fired the fatal shot. The prosecution indicated it was prepared to show Mr. Banks was going to "'take the beef'" because he was going to the Youth Authority and "'couldn't get hurt,'" and because he had been threatened with harm if he refused to so testify. ( Id. at p. 878.) The trial court ruled the third-party culpability evidence, i.e., the statements against penal interest, was inadmissible as untrustworthy. ( Id. at pp. 878-879.) The Court of Appeal concluded the trial court's determination of untrustworthiness was well supported by the evidence. ( Id. at p. 880.) As discussed above, a preliminary showing of trustworthiness was required under Evidence Code section 1230. The Court of Appeal went on to hold, however, that the trial court had also acted "well within its discretion in excluding the evidence under Evidence Code section 352." ( Id. at p. 881.) The Chapman court reasoned that: evidence that "simply points to a possible grounds of suspicion against another person" is generally inadmissible in a criminal case; the evidence offered was complex, intricate, and open to impeachment; the "possibility of confusing the issues and misleading the jury is patent"; and in applying Evidence Code section 352 the trial court necessarily considered the credibility of the witnesses who testified to the third party's statements against penal interest. (Ibid.)