MRE 804(B)(3) Interpretation
In People v. Poole, 444 Mich 151; 506 NW2d 505 (1993), the Supreme Court of Michigan addressed the similar trustworthiness requirement of the hearsay exception for statements against interest, MRE 804(b)(3). the Court held that the presence of the following factors would favor admission of such a statement:
Whether the statement was:
(1) voluntarily given;
(2) made contemporaneously with the events referenced;
(3) made to family, friends, colleagues, or confederates--that is, to someone to whom the declarant would likely speak the truth;
(4) uttered spontaneously at the initiation of the declarant and without prompting or inquiry by the listener. Id. at 165.