California, United States of America
The following excerpt is from People v. Titlow, A138713 (Cal. App. 2016):
" 'The focus of the declaration against interest exception to the hearsay rule is the basic trustworthiness of the declaration. . . . [T]he court may take into account not just the words but the circumstances under which they were uttered, the possible motivation of the declarant, and the declarant's relationship to the defendant.' [Citation.] . . . We have recognized that, in this context, assessing trustworthiness ' " 'requires the court to apply to the peculiar facts of the individual case a broad and deep acquaintance with the ways human beings actually conduct themselves in the circumstances material under the exception.' " ' " (People v. Geier (2007) 41 Cal.4th 555, 584 (Geier), overruled on other grounds as recognized by People v. Seumanu (2015) 61 Cal.4th 1293, 1320.)
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