California, United States of America
The following excerpt is from People v. Green, C087436 (Cal. App. 2020):
"We review a trial court's decision whether a statement is admissible under Evidence Code section 1230 for abuse of discretion. [Citations.]" (People v. Grimes (2016) 1 Cal.5th 698, 711.) " 'The proponent of such evidence must show "that the declarant is unavailable, that the declaration was against the declarant's penal interest,
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and that the declaration was sufficiently reliable to warrant admission despite its hearsay character." ' [Citation.] 'The focus of the declaration against interest exception to the hearsay rule is the basic trustworthiness of the declaration.' " (People v. Geier (2007) 41 Cal.4th 555, 584.)
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