The Confrontation Clause is inapplicable to out-of-court non-testimonial statements of codefendants.
A codefendant’s hearsay statement is admissible if it falls within an accepted exception or is supported by a guarantee of trustworthiness.
Admission of statements with sufficient indicia to fall within the hearsay exception for declarations against interest do not deny a defendant the right to confrontation.
In this complex murder case with multiple defendants, the court traced the admissibility of out-of-court statements by defendants implicating their codefendants in the offenses.