How has the court interpreted the rules of evidence in cases dealing with self-confessed statements made outside of court?

retain, moreover, a traditional and intrinsic power to exercise discretion to control the admission of evidence in the interests of orderly procedure and the avoidance of prejudice." (People v. Hall (1986) 41 Cal.3d 826, 834.) We do not discern any fundamental unfairness or denial of due process in the particular operation of the rules of evidence here.

Generally, evidence of a statement that was made other than by a witness while testifying at a hearing and that is offered to prove the truth of the matter stated is inadmissible hearsay. (Evid. Code, 1200.) However, "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." (People v. Lucas (1995) 12 Cal.4th 415, 454.) This exception is founded on the notion that a reasonable person would not make self-inculpatory statements unless that person believed them to be true. (Williamson v. U.S. (1994) 512 U.S. 594, 599.)

"A party who maintains that an out-of-court statement is admissible under this exception as a declaration against penal interest 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 (1993) 6 Cal.4th 585, 607.) It is this third requirement -- that the declaration be sufficiently reliable -- that the trial court found lacking here.