Williamson v. United States, 512 U.S. 594 (1994)

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certiorari to the united states court of appeals for the eleventh circuit

No. 93-5256. Argued April 25, 1994—Decided June 27, 1994

After Reginald Harris refused to testify at petitioner Williamson's federal trial on cocaine possession and distribution charges, the District Court ruled that, under Federal Rule of Evidence 804(b)(3)'s hearsay exception for statements against penal interest, a Drug Enforcement Administration agent could recount two custodial interviews in which Harris had freely confessed to receiving and transporting the drugs in question, but also implicated Williamson as the drugs' owner. Williamson was eventually convicted, and the Court of Appeals affirmed.

Held: The judgment is vacated, and the case is remanded.

981 F. 2d 1262, vacated and remanded.

Justice O'Connor delivered the opinion of the Court with respect to Parts I, II-A, and II-B, concluding: 1. The most faithful reading of Rule 804(b)(3)—which renders admissible "statement[s] which . . . so far ten[d] to subject the declarant to . . . criminal liability . . . that a reasonable person . . . would not have made [them] unless believing [them] to be true"—is that it does not allow admission of non-self-inculpatory statements, even if they are made within a broader narrative that is generally self-inculpatory. Although the statutory term "statement" can mean either an extended declaration or a single remark, the principle behind the Rule, so far as it is discernible from the text, points clearly to the narrower reading, so that only those remarks within a confession that are individually self-inculpatory are covered. The Rule is founded on the commonsense notion that reasonable people, even those who are not especially honest, tend not to make self-inculpatory statements unless they believe them to be true. This notion does not extend to a confession's non-self-inculpatory parts—to parts that are actually self-exculpatory, or to collateral statements, even ones that are neutral as to interest. A district court may not just assume that a statement is self-inculpatory because it is part of a fuller confession, especially when the statement implicates someone else. The policy expressed in the Rule's text is clear enough that it outweighs whatever force lies in ambiguous statements contained in the Advisory Committee Notes to the Rule. Pp. 598-602. 2. The foregoing reading does not eviscerate the against penal interest exception. There are many circumstances in which Rule 804(b)(3)

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