What rights of confrontation and confrontation under the Sixth Amendment?

The rights of confrontation and compulsory process under the Sixth Amendment, and the more general right to a fair trial under the Fifth Amendment, are not absolute. Rather, they are exercised in a framework of state law privileges, immunities, and rules of evidence that sometime block access to information needed by the defendant. (See Chambers v. Mississippi (1973) 410 U.S. 284, 302-303, 93 S.Ct. 1038, 1049-1050, 35 L.Ed.2d 297 [a holding that strikes down an unreasonable hearsay rule on due process grounds does not "signal any diminution in the respect traditionally accorded to the States in the establishment and implementation of their own [50 Cal.3d 819] criminal trial rules and procedures"]; Washington v. Texas (1967) 388 U.S. 14, 23, fn. 21, 87 S.Ct. 1920, 1925, fn. 21, 18 L.Ed.2d 1019 [a ruling that strikes down on compulsory process grounds a state law prohibiting coconspirators from testifying on each other's behalf does not invalidate traditional testimonial privileges].) While consistency has not been a hallmark in this area, courts have been extremely reluctant to make incursions into state law testimonial privileges--e.g., the attorney/client, priest/penitent, or marital communications privileges--on Sixth Amendment grounds. (See Note, Defendant v. Witness: Measuring Confrontation and Compulsory Process Rights Against Statutory Communications Privileges (1978) 30 Stan.L.Rev. 935 (hereafter Defendant v. Witness ).)