State v. Doctor

Toal, Justice:

The appellant, Doctor, was convicted of armed robbery. The issue presented in this appeal is whether the trial court erred in excluding out-of-court statements made against the declarant’s penal interest offered to exculpate the accused. We reverse.

FACTS

At trial the victim and sole eyewitness testified Doctor, accompanied by two other boys, approached him in a shopping mall parking lot and demanded his car keys. According to the victim, when he refused Doctor pointed a gun to his head. The victim then surrendered his keys and the three boys drove away in the car. The car was…