## Facts

- Reginald Harris was stopped while driving a rental car; a consensual search found 19 kilograms of cocaine in suitcases in the trunk.
- After his arrest, Harris gave DEA Agent Donald Walton custodial statements describing how he obtained and was transporting the cocaine.
- Harris’s accounts included assertions that the cocaine belonged to Fredel Williamson and that Harris was transporting it for delivery connected to Williamson.
- Harris later recanted an earlier account involving an unidentified “Cuban” and then claimed the “real story” was that he was transporting the cocaine to Atlanta for Williamson, who was driving ahead in another rental car.
- At Williamson’s federal trial for cocaine possession and distribution offenses, Harris was unavailable because he refused to testify despite immunity.
- Over objection, the trial court admitted Harris’s custodial statements through the DEA agent under Federal Rule of Evidence 804(b)(3), including portions implicating Williamson.

## Issues

1. Whether Federal Rule of Evidence 804(b)(3) permits admission of non-self-inculpatory assertions within an unavailable accomplice’s broader narrative that is generally self-inculpatory.
2. Whether a court must evaluate each component of an unavailable declarant’s statement separately to determine if it is against the declarant’s penal interest.

## Decision

- The Supreme Court vacated the judgment and remanded.
- Rule 804(b)(3) does not allow admission of non-self-inculpatory statements merely because they appear within a generally self-inculpatory confession.
- Only those portions of an unavailable declarant’s statement that are themselves individually self-inculpatory fall within Rule 804(b)(3).
- The lower courts were directed to determine, statement-by-statement, which parts of Harris’s statements were genuinely self-inculpatory and thus admissible, and which parts (including collateral assertions implicating Williamson) were not.

## Legal Principles

- For Rule 804(b)(3), “statement” is construed to require a segment-by-segment assessment, not automatic admission of an entire narrative once some portion is against interest.
- The reliability rationale for the against-interest exception applies to remarks that actually subject the declarant to criminal liability, not to collateral, neutral, self-exculpatory, or blame-shifting assertions.
- Courts may not treat a remark as against penal interest solely because it is embedded in a broader confession, particularly when it implicates another person.
- Accomplice confessions given in custody may contain incentives to minimize the declarant’s role or curry favor; only truly self-inculpatory parts satisfy Rule 804(b)(3).

## Conclusion

The Court limited Rule 804(b)(3) by requiring courts to parse an unavailable declarant’s narrative and admit only those parts that are individually self-inculpatory, excluding collateral assertions that primarily implicate someone else.


Williamson v. United States, 512 U.S. 594 (1994)