State v. Patel

Summary

The court affirmed the defendant’s convictions, holding that admission of a codefendant’s recorded statement to a jailhouse informant did not violate either federal or state confrontation protections and was permissible under the hearsay exception for statements against penal interest. The court also held that the trial court properly excluded a purported third party confession because the circumstances did not establish sufficient trustworthiness or corroboration. The court cautioned that materially different facts involving greater governmental orchestration could warrant a different constitutional result.