People v. Smith

*306SIMONS, J.,

Concurring.—I agree not only with the result reached by my colleagues in the majority, but also with their analysis of governing California Supreme Court precedent. I write separately in order to critique that precedent, which I believe has created an unjustified extra “reliability” requirement to admissibility under Evidence Code section 1230,1 the declaration against interest exception to the hearsay rule. (See, e.g., People v. Grimes (2016) 1 Cal.5th 698, 711 [207 Cal.Rptr.3d 1, 378 P.3d 320] (Grimes) [the proponent of admission of evidence under the exception “ ‘must show that…