In People v. Duke (1999) 74 Cal.App.4th 23, in a robbery-murder prosecution, the codefendant "voluntarily and spontaneously made his statements implicating the defendant to a friend within hours of committing the crimes." ( Duke, supra, 74 Cal.App.4th at p. 30.) The codefendant admitted his own involvement in the crime, the conversation took place before the declarant was a suspect, and it occurred under circumstances where there was no motive to lie. ( Id. at p. 31.) The Duke court upheld the trial court's determination that the statements met "the residual trustworthiness test of Lilly v. Virginia (1999)." (Ibid.)