Lilly v. Virginia: Answering the Williamson Question—Is the Statement Against Penal Interest Exception "Firmly Rooted" Under Confrontation Clause Analysis?

Authors

Kim Mark Minix

Publication Date

7-2000

Document Type

Casenote

Abstract

In Lilly v. Virginia the United States Supreme Court reaffirmed the principle that the statement against penal interest exception to the hearsay rule is too large a class for effective Confrontation Clause analysis. However, the Court held that confessional statements made by an accomplice that incriminate a criminal defendant, a subcategory of this exception, are not within a "firmly rooted" exception as recognized under the Confrontation Clause.

Recommended Citation

Minix, Kim Mark (2000) "Lilly v. Virginia: Answering the Williamson Question—Is the Statement Against Penal Interest Exception "Firmly Rooted" Under Confrontation Clause Analysis?," Mercer Law Review: Vol. 51: No. 4, Article 16.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol51/iss4/16