Alonzo v. State

The trial court did not abuse its discretion in refusing to admit the videotape of Kern, nor the testimony of Graham, Lip-chak, Miller, and O’Shields. The hearsay exception relied upon by Alonzo for the introduction of the videotape is Rule 803(24). That rule provides: “A statement tending to expose the declarant to criminal liability is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement.” Tex.R. Evid. 803(24). “The focus of this inquiry is on verifying to the greatest extent possible the trustworthiness of the statement so as to avoid the…