Admission of Hearsay Confessions of a Third Party
In Chambers v. Mississippi, 410 U.S. 284 (1973), the Supreme Court relied on the following factors to justify the admission of the hearsay confessions of a third party, despite state evidentiary rules to the contrary:
(1) each confession was made spontaneously to a close acquaintance after the murder occurred;
(2) each confession was corroborated by some other evidence in the case;
(3) each confession was self-incriminatory and unquestionably against interest;
(4) if there was any question as to the truthfulness of the statements, the declarant was available for cross-examination. See id. at 300.
As the Supreme Court observed about the statements:
"The hearsay statements involved in this case were originally made and subsequently offered at trial under circumstances that provided considerable assurance of their reliability." Id.
We have previously explained the facts and circumstances of Chambers:
"Another individual made three verbal confessions to this crime and one written confession which he later repudiated. The prosecution did not call this declarant as a witness so the defense did. At that time, under the "voucher" rule in Mississippi, one could not impeach one's own witness. Therefore, the defense was not allowed to have the verbal confessions admitted into evidence for that purpose. In addition, the hearsay rule prevented the testimony from being heard and Mississippi had no exception to the rule based on declarations against penal interest." Card v. State, 453 So. 2d 17, 21 (Fla. 1984).
The Supreme Court stated in Chambers that it was establishing no new standards of constitutional law, nor was it diminishing the authority of the states over their own trial rules. Chambers, 410 U.S. at 302.