State v. Standifur

McAULIFFE, Judge.

This case presents the question of whether a declaration against the penal interest of an unavailable witness, offered by the State against the accused in a criminal trial, is sufficiently reliable to qualify under the common law exception to the hearsay rule and to satisfy the Confrontation Clauses of the Constitution of the United States and the Declaration of Rights of Maryland.

The Appellees, Larry Ramoun Standifur and Colonel Hillard Henry, were indicted on various, criminal charges as accomplices in the same criminal episode, but were tried separately. Henry was tried by…