Cite as: 527 U. S. 116 (1999)
Opinion of Stevens, J.
the time it is made." Chambers v. Mississippi, 410 U. S. 284, 299 (1973).
We have previously noted that, due to the sweeping scope of the label, the simple categorization of a statement as a " 'declaration against penal interest' . . . defines too large a class for meaningful Confrontation Clause analysis." Lee v. Illinois, 476 U. S., at 544, n. 5. In criminal trials, statements against penal interest are offered into evidence in three principal situations: (1) as voluntary admissions against the declarant; (2) as exculpatory evidence offered by a defendant who claims that the declarant committed, or was involved in, the offense; and (3) as evidence offered by the prosecution to establish the guilt of an alleged accomplice of the declarant. It is useful to consider the three categories and their roots separately.
Statements in the first category—voluntary admissions of the declarant—are routinely offered into evidence against the maker of the statement and carry a distinguished heritage confirming their admissibility when so used. See G. Gilbert, Evidence 139-140 (1756); Lambe's Case, 2 Leach 552, 168 Eng. Rep. 379 (1791); State v. Kirby, 1 Strob. 155, 156 (1846); State v. Cowan, 29 N. C. 239, 246 (1847). Thus, assuming that Mark Lilly's statements were taken in conformance with constitutional prerequisites, they would unquestionably be admissible against him if he were on trial for stealing alcoholic beverages.
If Mark were a codefendant in a joint trial, however, even the use of his confession to prove his guilt might have an adverse impact on the rights of his accomplices. When dealing with admissions against penal interest, we have taken great care to separate using admissions against the declarant (the first category above) from using them against other criminal defendants (the third category).
In Bruton v. United States, 391 U. S. 123 (1968), two co-defendants, Evans and Bruton, were tried jointly and convicted of armed postal robbery. A postal inspector testified
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