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

Williamson v. United States

No. 93-5256

Argued April 25, 1994
Decided June 27, 1994
512 U.S. 594

CERTIORARI TO THE UNITED STATES COURT OF APPEALS

FOR THE ELEVENTH CIRCUIT

Syllabus

After Reginald Harris refused to testify at petitioner Williamson’s federal trial on cocaine possession and distribution charges, the District Court ruled that, under Federal Rule of Evidence 804(b)(3)’s hearsay exception for statements against penal interest, a Drug Enforcement Administration agent could recount two custodial interviews in which Harris had freely confessed to receiving and transporting the drugs in question, but also implicated Williamson as the drugs’ owner. Williamson was eventually convicted, and the Court of Appeals affirmed.

Held: The judgment is vacated, and the case is remanded.

981 F.2d 1262, vacated and remanded.

JUSTICE O’CONNOR delivered the opinion of the Court with respect to Parts I, II-A, and II-B, concluding:

1. The most faithful reading of Rule 804(b)(3) -- which renders admissible

statement[s] which . . . so far ten[d] to subject the declarant to . . . criminal liability . . . that a reasonable person . . . would not have made [them] unless believing [them] to be true

-- is that it does not allow admission of non-self-inculpatory statements, even if they are made within a broader narrative that is generally self-inculpatory. Although the statutory term "statement" can mean either an extended declaration or a single remark, the principle behind the Rule, so far as it is discernible from the text, points clearly to the narrower reading, so that only those remarks within a confession that are individually self-inculpatory are covered. The Rule is founded on the common sense notion that reasonable people, even those who are not especially honest, tend not to make self-inculpatory statements unless they believe them to be true. This notion does not extend to a confession’s non-self-inculpatory parts -- to parts that are actually self-exculpatory, or to collateral statements, even ones that are neutral as to interest. A district court may not just assume that a statement is self-inculpatory because it is part of a fuller confession, especially when the statement implicates someone else. The policy expressed in the Rule’s text is clear enough that it outweighs whatever force lies in ambiguous statements contained in the Advisory Committee Notes to the Rule. Pp. 598-602.

2. The foregoing reading does not eviscerate the against penal interest exception. There are many circumstances in which Rule 804(b)(3) does allow the admission of statements that inculpate a criminal defendant. Even the confessions of arrested accomplices may be admissible if they are truly self-inculpatory, rather than merely attempts to shift blame or curry favor. The question under the Rule is always whether the statement at issue was sufficiently against the declarant’s penal interest under the Rule’s language, and this question can only be answered in light of all the surrounding circumstances. Pp. 602-604.

JUSTICE O’CONNOR, joined by JUSTICE SCALIA, concluded in Part II-C that, on remand, the Court of Appeals must inquire in the first instance whether each of the statements in Harris’ confession was truly self-inculpatory. Pp. 604-605.

O’CONNOR, J., announced the judgment of the Court and delivered the opinion of the Court with respect to Parts I, II-A, and II-B, in which BLACKMUN, STEVENS, SCALIA, SOUTER, and GINSBURG, JJ., joined, and an opinion with respect to Part II-C, in which SCALIA, J., joined. SCALIA, J., filed a concurring opinion, post, p. 605. GINSBURG, J., filed an opinion concurring in part and concurring in the judgment, in which BLACKMUN, STEVENS, and SOUTER, JJ., joined, post, p. 607. KENNEDY, J., filed an opinion concurring in the judgment, in which REHNQUIST, C.J., and THOMAS, J., joined, post, p. 611.