Williamson v. United States 512 U.S. 594, 114 S.Ct. 2431, 129 L.Ed.2d 476 (1994)
A search of Harris' car turned up 19 kgs of cocaine. He
Harris told a DEA agent that the cocaine belonged to
Harris told two contradictory stories about the cocaine,
though both involved Williamson.
Harris refused to sign a written statement or testify at
trial because he claimed he was afraid of Williamson.
Williamson was arrested and charged with drug trafficking.
At trial, the prosecution attempted to introduce Harris'
statements into evidence. Williamson objected.
Williamson argued that Harris' statements were hearsay.
The prosecution argued that they were admissible as statements
against interest by a now unavailable witness under the FRE
The Trial Judge admitted Harris' statement.
The Trial Court convicted Williamson of drug trafficking.
The Appellate Court affirmed. Williamson appealed.
The US Supreme Court reversed.
The US Supreme Court found that in order for a statement
to be admissible under FRE 804(b)(3) the statement must be clearly
against the declarant's penal interest and that a reasonable person in
the declarant's position would not have made the statement unless
believing it to be true.
Harris admitted to possessing the drugs. Claiming that
they belonged to Williamson was not self-incriminating, in fact it was
exculpatory. Therefore, the statement was not against Harris' interest
and is not covered by the FRE 804(b)(3) exception.
Harris' statements "provided only marginal evidence
of his guilt. They project an image of a person action not against his
penal interest, but striving mightily to shift principle responsibility
to someone else."