corroboration inquiry in New Mexico

2017See United States v. Bryce, 208 F.3d 346, 355-56 (2d Cir. 1999) (requiring corroboration for unknowingly wiretapped statements and creating, without any authority, two categories of statements made in the course of a crime and not requiring corroboration for only one category—those in the nature of self-corroborating statements, which did not include the wiretapped statements); United States v. Marshall, 863 F.2d 1285, 1286-87 (6th Cir. 1988) (stating that the corroboration requirement is only for post-offense statements, but nevertheless, the court required corroboration for statements made t

2017See United States v. Bryce, 208 F.3d 346 , 8 355-56 (2d Cir. 1999) (requiring corroboration for unknowingly wiretapped 9 statements and creating, without any authority, two categories of statements made in 10 the course of a crime and not requiring corroboration for only one category—those 11 in the nature of self-corroborating statements, which did not include the wiretapped 12 statements); United States v. Marshall, 863 F.2d 1285, 1286-87 (6th Cir. 1988) 13 (stating that the corroboration requirement is only for post-offense statements, but 14 nevertheless, the court required corroboration f

2017See United States v. Bryce, 208 F.3d 346, 355-56 (2d Cir. 1999) (requiring corroboration for unknowingly wiretapped statements and creating, without any authority, two categories of statements made in the course of a crime and not requiring corroboration for only one category—those in the nature of self-corroborating statements, which did not include the wiretapped statements); United States v. Marshall, 863 F.2d 1285, 1286-87 (6th Cir. 1988) (stating that the corroboration requirement is only for post-offense statements, but nevertheless, the court required corroboration for statements made t

2017See United States v. Bryce, 208 F.3d 346 , 8 355-56 (2d Cir. 1999) (requiring corroboration for unknowingly wiretapped 9 statements and creating, without any authority, two categories of statements made in 10 the course of a crime and not requiring corroboration for only one category—those 11 in the nature of self-corroborating statements, which did not include the wiretapped 12 statements); United States v. Marshall, 863 F.2d 1285, 1286-87 (6th Cir. 1988) 13 (stating that the corroboration requirement is only for post-offense statements, but 14 nevertheless, the court required corroboration f

2017See United States v. Bryce, 208 F.3d 346, 355-56 (2d Cir. 1999) (requiring corroboration for unknowingly wiretapped statements and creating, without any authority, two categories of statements made in the course of a crime and not requiring corroboration for only one category—those in the nature of self-corroborating statements, which did not include the wiretapped statements); United States v. Marshall, 863 F.2d 1285, 1286-87 (6th Cir. 1988) (stating that the corroboration requirement is only for post-offense statements, but nevertheless, the court required corroboration for statements made t

2017See United States v. Bryce, 208 F.3d 346 , 8 355-56 (2d Cir. 1999) (requiring corroboration for unknowingly wiretapped 9 statements and creating, without any authority, two categories of statements made in 10 the course of a crime and not requiring corroboration for only one category—those 11 in the nature of self-corroborating statements, which did not include the wiretapped 12 statements); United States v. Marshall, 863 F.2d 1285, 1286-87 (6th Cir. 1988) 13 (stating that the corroboration requirement is only for post-offense statements, but 14 nevertheless, the court required corroboration f

2017See United States v. Bryce, 208 F.3d 346, 355-56 (2d Cir. 1999) (requiring corroboration for unknowingly wiretapped statements and creating, without any authority, two categories of statements made in the course of a crime and not requiring corroboration for only one category—those in the nature of self-corroborating statements, which did not include the wiretapped statements); United States v. Marshall, 863 F.2d 1285, 1286-87 (6th Cir. 1988) (stating that the corroboration requirement is only for post-offense statements, but nevertheless, the court required corroboration for statements made t

2017See United States v. Bryce, 208 F.3d 346 , 8 355-56 (2d Cir. 1999) (requiring corroboration for unknowingly wiretapped 9 statements and creating, without any authority, two categories of statements made in 10 the course of a crime and not requiring corroboration for only one category—those 11 in the nature of self-corroborating statements, which did not include the wiretapped 12 statements); United States v. Marshall, 863 F.2d 1285, 1286-87 (6th Cir. 1988) 13 (stating that the corroboration requirement is only for post-offense statements, but 14 nevertheless, the court required corroboration f

2017Nev. 1980) (explaining that the Ninth Circuit has taken internally inconsistent approaches to the timing of the statements and to whom they are made and holding that statements made by a conspirator to an investigator in the life of the conspiracy but after the termination of the conspirator’s participation in the conspiracy required corroboration); United States v. Hallman, 594 F.2d 198, 201 (9th Cir. 1979) (“[T]he corroboration rule applies only to confessions or admissions made in the course of the commission of the offense or in the course of investigation.”); United States v. Tourine, 428

2017Nev. 1980) (explaining that the Ninth 5 Circuit has taken internally inconsistent approaches to the timing of the statements 6 and to whom they are made and holding that statements made by a conspirator to an 7 investigator in the life of the conspiracy but after the termination of the conspirator’s 8 participation in the conspiracy required corroboration); United States v. Hallman, 594 9 F.2d 198, 201 (9th Cir. 1979) (“[T]he corroboration rule applies only to confessions 10 or admissions made in the course of the commission of the offense or in the course 11 of investigation.”); United States

2017See United States v. Bryce, 208 F.3d 346, 355-56 (2d Cir. 1999) (requiring corroboration for unknowingly wiretapped statements and creating, without any authority, two categories of statements made in the course of a crime and not requiring corroboration for only one category—those in the nature of self-corroborating statements, which did not include the wiretapped statements); United States v. Marshall, 863 F.2d 1285, 1286-87 (6th Cir. 1988) (stating that the corroboration requirement is only for post-offense statements, but nevertheless, the court required corroboration for statements made t

2017See United States v. Bryce, 208 F.3d 346 , 8 355-56 (2d Cir. 1999) (requiring corroboration for unknowingly wiretapped 9 statements and creating, without any authority, two categories of statements made in 10 the course of a crime and not requiring corroboration for only one category—those 11 in the nature of self-corroborating statements, which did not include the wiretapped 12 statements); United States v. Marshall, 863 F.2d 1285, 1286-87 (6th Cir. 1988) 13 (stating that the corroboration requirement is only for post-offense statements, but 14 nevertheless, the court required corroboration f

2017Nev. 1980) (explaining that the Ninth Circuit has taken internally inconsistent approaches to the timing of the statements and to whom they are made and holding that statements made by a conspirator to an investigator in the life of the conspiracy but after the termination of the conspirator’s participation in the conspiracy required corroboration); United States v. Hallman, 594 F.2d 198, 201 (9th Cir. 1979) (“[T]he corroboration rule applies only to confessions or admissions made in the course of the commission of the offense or in the course of investigation.”); United States v. Tourine, 428

2010See United States v. Shunk, 881 F.2d 917, 919 (10th Cir.1989) (“As it presently exists, the corpus delicti concept has been properly characterized as a ‘version’ of the corroboration requirement for the introduction of extrajudicial statements.”).

1999See State v. Anaya, 89 N.M. 302, 304 , 551 P.2d 992, 994 (Ct.App.1976). {7} Construction of Fed.R.Evid. 804(b)(3), which is nearly identical to Rule 11-804(B)(3), guides our analysis.

1999See State v. Anaya, 89 N.M. 302, 304 , 551 P.2d 992, 994 (Ct.App.1976). {7} Construction of Fed.R.Evid. 804(b)(3), which is nearly identical to Rule 11-804(B)(3), guides our analysis.

1998The trial court, relying on Sanchez, 112 N.M. at 63 , 811 P.2d at 96 , considered independent corroborative evidence in admitting Barnett's statement; however, given the fact that the statement met all three of the remaining Earnest factors, we do not believe that the consideration of independent evidence affected the trial court's ultimate conclusion that the statement was sufficiently reliable to satisfy the Confrontation Clause. [5] "The weight of authority, post Lee v. Illinois and Williamson , supports the conclusion that the exception to the hearsay rule for a statement against penal int

1998The trial court, relying on Sanchez, 112 N.M. at 63 , 811 P.2d at 96 , considered independent corroborative evidence in admitting Barnett's statement; however, given the fact that the statement met all three of the remaining Earnest factors, we do not believe that the consideration of independent evidence affected the trial court's ultimate conclusion that the statement was sufficiently reliable to satisfy the Confrontation Clause. [5] "The weight of authority, post Lee v. Illinois and Williamson , supports the conclusion that the exception to the hearsay rule for a statement against penal int

1998The trial court, relying on Sanchez, 112 N.M. at 63 , 811 P.2d at 96 , considered independent corroborative evidence in admitting Barnett's statement; however, given the fact that the statement met all three of the remaining Earnest factors, we do not believe that the consideration of independent evidence affected the trial court's ultimate conclusion that the statement was sufficiently reliable to satisfy the Confrontation Clause. [5] "The weight of authority, post Lee v. Illinois and Williamson , supports the conclusion that the exception to the hearsay rule for a statement against penal int

1998Cf. Newton, 966 P.2d at 574 (limiting a corroboration inquiry pursuant to the hearsay exception for declarations against penal interest to the circumstances surrounding the making of the statement and excluding from the inquiry independent evidence introduced at trial in order to be consistent with the Confrontation Clause).

1998Cf. Newton, 966 P.2d at 574 (limiting a corroboration inquiry pursuant to the hearsay exception for declarations against penal interest to the circumstances surrounding the making of the statement and excluding from the inquiry independent evidence introduced at trial in order to be consistent with the Confrontation Clause).

1998The trial court, relying on Sanchez, 112 N.M. at 63 , 811 P.2d at 96 , considered independent corroborative evidence in admitting Barnett's statement; however, given the fact that the statement met all three of the remaining Earnest factors, we do not believe that the consideration of independent evidence affected the trial court's ultimate conclusion that the statement was sufficiently reliable to satisfy the Confrontation Clause. [5] "The weight of authority, post Lee v. Illinois and Williamson , supports the conclusion that the exception to the hearsay rule for a statement against penal int

1998The trial court, relying on Sanchez, 112 N.M. at 63 , 811 P.2d at 96 , considered independent corroborative evidence in admitting Barnett's statement; however, given the fact that the statement met all three of the remaining Earnest factors, we do not believe that the consideration of independent evidence affected the trial court's ultimate conclusion that the statement was sufficiently reliable to satisfy the Confrontation Clause. [5] "The weight of authority, post Lee v. Illinois and Williamson , supports the conclusion that the exception to the hearsay rule for a statement against penal int

1998The trial court, relying on Sanchez, 112 N.M. at 63 , 811 P.2d at 96 , considered independent corroborative evidence in admitting Barnett's statement; however, given the fact that the statement met all three of the remaining Earnest factors, we do not believe that the consideration of independent evidence affected the trial court's ultimate conclusion that the statement was sufficiently reliable to satisfy the Confrontation Clause. [5] "The weight of authority, post Lee v. Illinois and Williamson , supports the conclusion that the exception to the hearsay rule for a statement against penal int

1998The trial court, relying on Sanchez, 112 N.M. at 63 , 811 P.2d at 96 , considered independent corroborative evidence in admitting Barnett's statement; however, given the fact that the statement met all three of the remaining Earnest factors, we do not believe that the consideration of independent evidence affected the trial court's ultimate conclusion that the statement was sufficiently reliable to satisfy the Confrontation Clause. [5] "The weight of authority, post Lee v. Illinois and Williamson , supports the conclusion that the exception to the hearsay rule for a statement against penal int

1972See State v. Borunda, 83 N.M. 563 , 494 P.2d 976 (Ct.App.1972).

1972See State v. Borunda, 83 N.M. 563 , 494 P.2d 976 (Ct.App.1972).