Williamson v. United States

Supreme Court of the United States · 1994 · Evidence

512 U.S. 594 (1994)

Updated August 1, 2026

Evidencestatements against interesthearsayFed. R. Evid. 804(b)(3)statement against penal interestself-inculpatory statementscollateral statementscodefendant confession

Facts

After a deputy sheriff stopped Reginald Harris' rental car and found 19 kilograms of cocaine in the trunk, Harris gave DEA Agent Walton several statements about the drugs. Harris implicated himself in transporting the cocaine but also said the cocaine belonged to Williamson and was being delivered for him; later Harris admitted parts of his first story were false and gave a different account still implicating Williamson. At Williamson's trial, Harris refused to testify despite immunity and a court order, so the district court admitted Walton's account of Harris' statements under Rule 804(b)(3). Williamson argued those statements, especially the parts implicating him, were inadmissible hearsay.

Issue

Under Federal Rule of Evidence 804(b)(3), does a broader confession become admissible as a statement against penal interest in its entirety, including parts that are not themselves self-inculpatory but implicate another person? Must courts assess each remark separately to determine whether it is truly against the declarant's penal interest?

Rule

Rule 804(b)(3) does not permit admission of non-self-inculpatory statements merely because they are contained within a broader narrative that is generally self-inculpatory. The court must determine, in light of all surrounding circumstances, whether each particular declaration or remark was sufficiently against the declarant's penal interest that a reasonable person in the declarant's position would not have made it unless believing it to be true.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Police in Nashville stopped a van driven by Trent Lawson and found stolen medical equipment inside. Trent later refused to testify at Maya Chen's trial, and the prosecution sought to introduce an officer's account that Trent said, "I knew the equipment was stolen, and Maya told me where to drop it off."

Under Rule 804(b)(3), which is the best ruling on this hearsay statement?

Explanation. Rule 804(b)(3) applies to particular declarations or remarks that are themselves against the declarant's penal interest. A court may not admit non-self-inculpatory portions simply because they are embedded in a generally inculpatory confession. Trent's admission that he knew the goods were stolen is self-inculpatory; the separate assertion that Maya directed the drop-off is not automatically admissible just because it accompanies the inculpatory part.