In White v. Illinois, 502 U.S. 346 (1992), the Court was considering whether the Confrontation Clause required the prosecution to produce the declarant at trial or prove the declarant unavailable before admitting testimony under the "'spontaneous declaration'" or "'medical examination'" exceptions to the hearsay rule. White, 502 U.S. at 348. In White, supra, the Court stated that where proffered hearsay has sufficient guarantees of reliability to come within a firmly rooted exception to the hearsay rule, the Confrontation Clause is satisfied. The Court further indicated that a statement that qualifies for admission under a "'firmly rooted'" hearsay exception is so trustworthy that adversarial testing can be expected to add little to its reliability. Id. at 357. The Court then held that under the Confrontation Clause, precedent did not require evidence embraced within such exceptions to the hearsay rule as those for spontaneous declarations and statements made for medical treatment to be excluded from trial. Id.