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 rights and was admissible as a statement against penal interest. The statement was objectively nontestimonial because the encounter was informal and its purpose was not to obtain trial testimony, and the statement was sufficiently trustworthy because it was strongly corroborated and heavily against the declarant's penal interest. The court also held that the trial court properly excluded an alleged third party confession because the surrounding circumstances did not establish sufficient trustworthiness.