Robinson v. State
In Robinson v. State, 11 P.3d 361 (Wyo. 2000), the Court found that hearsay statements were properly admitted under the "against penal interest" exception to the hearsay rule.
Without deciding whether the exception was firmly rooted, the statement was deemed trustworthy because:
(1) the statements implicated the victim in misconduct other than the crime for which the defendant was convicted;
(2) the statements did not invoke the confession of an accomplice;
(3) they were not made to shift blame or for some other improper motive such as courting favor with authorities. (Robinson, 11 P.3d at 371.)