Can an out-of-court declaration of an unavailable witness be admitted for its truth?

Evidence Code section 1230 provides that the out-of-court declaration of an unavailable witness may be admitted for its truth if the statement, when made, was against the declarant's penal interest. The proponent of such evidence must show "that the declarant is unavailable, that the declaration was against the declarant's penal interest, and that the declaration was sufficiently reliable to warrant admission despite its hearsay character." (People v. Cudjo, supra, 6 Cal.4th 585, 607, 25 Cal.Rptr.2d 390, 863 P.2d 635.) A trial court determining whether the proffered evidence is sufficiently reliable " 'may take into account not just the words but the circumstances under which they were uttered, the possible motivation of the declarant,

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