In United States v. Desena, 260 F.3d 150 (2d Cir. 2001), the court's analysis of corroboration focused only on the trustworthiness of the out-of-court statement, and not on that of the declarant or the witness who related the statement.
The court concluded that the declarant's statement was admissible as a declaration against penal interest because the declarant, who had invoked his Fifth Amendment right not to testify, was unavailable; the declarant's admission of arson was a statement against penal interest; and the trustworthiness of the statement was corroborated by the testimony of another witness, "whose description of the scene of the arson the day of the crime (a) matched the declarant's description of the defendant's actions and (b) substantiated the motive offered by the declarant. Id. at 158-59.