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Opinion of Stevens, J.
on the very gallows, by the true culprit now beyond the reach of justice." 5 J. Wigmore, Evidence § 1477, pp. 289-290 (3d ed. 1940).
See also Scolari v. United States, 406 F. 2d 563, 564 (CA9 1969) (criticizing Donnelly); United States v. Annunziato, 293 F. 2d 373, 378 (CA2 1961) (Friendly, J.) (same); Hines v. Commonwealth, 136 Va. 728, 117 S. E. 843 (1923) (criticizing Donnelly and refusing to incorporate it into state law); Wright, Uniform Rules and Hearsay, 26 U. Cin. L. Rev. 575 (1957).
Finally, in 1973, this Court endorsed the more enlightened view in Chambers, holding that the Due Process Clause affords criminal defendants the right to introduce into evidence third parties' declarations against penal interest— their confessions—when the circumstances surrounding the statements "provid[e] considerable assurance of their reliability." 410 U. S., at 300. Not surprisingly, most States have now amended their hearsay rules to allow the admission of such statements under against-penal-interest exceptions. See 5 J. Wigmore, Evidence § 1476, p. 352, and n. 9 (J. Chadbourn rev. 1974); id., § 1477, at 360, and n. 7; J. Wigmore, Evidence §§ 1476 and 1477, pp. 618-626 (A. Best ed. Supp. 1998). But because hearsay statements of this sort are, by definition, offered by the accused, the admission of such statements does not implicate Confrontation Clause concerns. Thus, there is no need to decide whether the reliability of such statements is so inherently dependable that they would constitute a firmly rooted hearsay exception.
The third category includes cases, like the one before us today, in which the government seeks to introduce "a confession by an accomplice which incriminates a criminal defendant." Lee, 476 U. S., at 544, n. 5. The practice of admitting statements in this category under an exception to the hearsay rule—to the extent that such a practice exists in certain jurisdictions—is, unlike the first category or even the second, of quite recent vintage. This category also typically
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