Case name: Williamson v. United StatesOpinion filed: 1994-06-27Docket No.: 93-5256Citations:• 129 L. Ed. 2d 476• 114 S. Ct. 2431• 512 U.S. 594• 1994 U.S. LEXIS 4832Case holding summaries:• "Rule 804(b)(3) is founded on the commonsense notion that reasonable people, even reasonable people who are not especially honest, tend not to make self-inculpatory statements unless they believe them to be true."• 'Self-exculpatory statements are exactly the ones which people are most liµely to maµe even when they are false; and mere proximity to other, self-inculpatory, statements does not increase the plausibility of the self- exculpatory statements.'• “Self-exculpatory statements are exactly the ones which people are most likely to make even when they are false”• Federal Rule of Evidence 804(b)(3) allows trial courts to admit, as a hearsay exception, only those statements which are themselves self-inculpatory• “A person arrested in incriminating circumstances has a strong incen- tive to shift blame or downplay his own role in comparison 6 No. 03-3756 with that of others, in hopes of receiving a shorter sentence and leniency in exchange for cooperation.”• “Self-exculpatory statements are exactly the ones which people are most likely to make even when they are false”• “The hearsay rule . . . is premised on the theory that out-of- court statements are subject to particular hazards.”• "[T]he very fact that a statement is genuinely self-inculpatory ...is itself one of the 'particularized guarantees of trustworthiness' that makes a statement admissible under the Confrontation Clause."• "[T]he most faithful reading of Rule 804(b)(3) is that it does not allow admission of non-self-inculpatory statements, even if they are made within a broader narrative that is generally self-inculpatory."• "Rule 804(b)(3) is founded on the commonsense notion that reasonable people, even reasonable people who are not especially honest, tend not to make self-inculpatory statements unless they believe them to be true."• holding that the statement against interest exception to the rule against hearsay does not extend to collateral statements within a statement against interest even when those collateral statements are neutral as to interest• explaining that all the surrounding circumstances must be considered to determine if a reasonable person would not have made the statement unless that person believed it to be true• explaining that "whether a statement is self-inculpatory or not can only be determined by viewing it in context," and that "[e]ven statements that are on their face neutral may actually be against the declarant's interest"• "[W]hether a statement is self-inculpatory or not can only be determined by viewing it in context."• finding proximity to self- inculpatory statements does not make non-inculpatory collateral statements admissible• observing that the “arrest statements of a codefendant have traditionally been viewed with special suspicion”• "Rule 804(b)(3) is founded on the commonsense notion that reasonable people, even reasonable people who are not especially honest, tend not to make self-inculpatory statements unless they believe them to be true."• "Rule 804(b)(3) is founded on the commonsense notion that reasonable people, even reasonable people who are not especially honest, tend not to make self-inculpatory statements unless they believe them to be true."• holding that a court may admit only those portions of a declarant's statement that are truly self-inculpatory• scope of the Rule 804(b)(3) exception to the hearsay rule does "not allow admission of non-self-inculpatory statements, even if they are made within a broader narrative that is generally self-inculpatory," which is especially true of statements that inculpate others• statement to police officer incriminating another is not a statement against declarant's penal interest within the meaning of Rule 804(b)(3), even if it is included within a broader narrative that is generally self-inculpatory• "We see no reason why collateral statements, even ones that are neutral as to interest ... should be treated any differently from other hearsay statements that are generally excluded."• “[T]he fact that a statement is collateral to a self-inculpatory statement says nothing at all about the collateral statement’s reliability.”• "[The declarant] might well have been motivated to misrepresent the role of others in the criminal enterprise, and might well have viewed the statement[s] as a wholeincluding the ostensibly disserving portionsto be in his interest rather than against it."• declarant not motivated by desire to curry favor; "voluntarily made his statement after being advised of his Miranda rights and did not enter into any plea agreements with the government"• holding that the exception is firmly rooted• Notes are to be given some weight• "[I]f Congress intends for legislation to change the interpretation of a judicially created concept, it makes that intent specific"• "when one person accuses another of a crime under circumstances in which the declarant stands to gain by inculpating another, the accusation is presumptively suspect and must be subjected to the scrutiny of cross-examination"• "`[T]he arrest statements of a codefendant have traditionally been viewed with special suspicion. Due to his strong motivation to implicate the defendant and to exonerate himself, a codefendant's statements about what the defendant said or did are less credible than ordinary hearsay evidence.' "• error requires reversal of criminal conviction if it is "highly probable that the error had substantial and injurious effect or influence in determining the jury's verdict"• court should not "imput[e] to Congress a purpose to paralyze with one hand what it sought to promote with the other"• "[R]easonable people, even reasonable people who are not especially honest, tend not to make self-inculpatory statements unless they believe them to be true."• explaining that context informs whether a statement is self-inculpatory or not• “‘Sam and I went to Joe’s house’ might be against the declarant’s interest if a reasonable person in the declarant’s shoes would realize that being linked to Joe and Sam would implicate the declarant in Joe and Sam’s conspiracy.”• “Even the confessions of arrested accomplices may be admissible if they are truly self-inculpatory, rather than merely attempts to shift blame or curry favor.”• finding part of a statement admissible under Rule 804(b)(3) and reasoning that “the most faithful reading of Rule 804(b)(3) is that it does not allow admission of non-self-inculpatory statements, even if they are made within a broader narrative that is generally self-inculpatory.”• holding that a similar federal rule applies narrowly only to those declarations or remarks in a confession that are individually self-inculpatory• observing that "[o]ne of the most effective ways to lie is to mix falsehood with truth, especially truth that seems particularly persuasive because of its self-incuplatory nature"• noting that "a declarant's squarely self-inculpatory confession... will likely be admissible under Rule 804(b)(3) against accomplices of his who are being tried under a co-conspirator liability theory" (citation omitted)• Rule 804(b)(3) "does not allow admission of non-self-inculpatory statements, even if they are made within a broader narrative that is generally self-inculpatory"• holding that Fed.R.Evid. 804(b)(3) "does not allow admission of non-self-inculpatory statements, even if they are made within a broader narrative that is generally self-inculpatory"• explaining that a declarant's statement as to where he hid a gun would be self- inculpatory "if it is likely to help the police find the murder weapon"• [d]ue to his strong motivation to implicate the defendant and to exonerate himself, a codefendant's statements about what the defendant said or did are less credible than ordinary hearsay evidence ...• "that a person is making a broadly self-inculpatory confession does not make more credible the confession's non-self-inculpatory parts"• construing Federal Rule of Evidence 804(b)(3) to permit only self-inculpatory statements to be admitted into evidence• noting that judges in federal cases must separate the incriminatory portions of statements from other portions for purposes of Rule 804(b)(3• finding that non-inculpatory statements are not admissible even if made within a broader context of a generally inculpatory narrative• "Self-exculpatory statements are exactly the ones which people are most likely to make even when they are false"• "A person arrested in incriminating circumstances has a strong incentive to shift blame or downplay his own role in comparison with that of others, in hopes of receiving a shorter sentence and leniency in exchange for cooperation."