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.
Minix, Kim Mark
"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
, Article 16.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol51/iss4/16