Nev. Rev. Stat. » NRS: CHAPTER 51 - HEARSAY
Nevada Revised Statutes

Nev. Rev. Stat. § 51.345 (2026)

Statement against interest

✓ current as of July 2026
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NRS 51.345  Statement against interest.

      1.  A statement which at the time of its making:

      (a) Was so far contrary to the pecuniary or proprietary interest of the declarant;

      (b) So far tended to subject the declarant to civil or criminal liability;

      (c) So far tended to render invalid a claim by the declarant against another; or

      (d) So far tended to make the declarant an object of hatred, ridicule or social disapproval,

Ê that a reasonable person in the position of the declarant would not have made the statement unless the declarant believed it to be true is not inadmissible under the hearsay rule if the declarant is unavailable as a witness. A statement tending to expose the declarant to criminal liability and offered to exculpate the accused in a criminal case is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement.

      2.  This section does not make admissible a statement or confession offered against the accused made by a codefendant or other person implicating both himself or herself and the accused.

      (Added to NRS by 1971, 797; A 1979, 44; 1997, 1592)

     

Notes of Decisions
Cited in 38 cases (4 in the last 5 years), 1972–2025 · leading case: Guy v. State, 839 P.2d 578 (Nev. 1992).
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Guy v. State, 839 P.2d 578 (Nev. 1992). · cites it 6× “315, or NRS 51.345. [3] We disagree. At trial, when appellant asked the state's witness to recount Pendleton's out-of-court statement, the state responded with a hearsay objection.”
Woods v. State, 696 P.2d 464 (Nev. 1985). · cites it 7× “Defense counsel then sought to introduce Murnighan’s testimony under NRS 51.345. The district court refused to allow Murnighan to testify because it did not consider her testimony sufficiently trustworthy to be admissible under the statute.”
State v. Bennett, 81 P.3d 1 (Nev. 2003). · cites it 2× “The State cites NRS 51.345(1), which requires such circumstances for the admission of a "statement tending to expose the declarant to criminal liability and offered to exculpate the accused in a criminal case.”
Walker v. State, 6 P.3d 477 (Nev. 2000). · cites it 5× “Pursuant to NRS 51.345, a statement against penal interest is admissible if: (1) at the time of its making, the statement tends to subject the declarant to civil or criminal liability; (2) a reasonable person in that position would not have made the statement unless he believed…”
State v. Parris, 654 P.2d 77 (Wash. 1982). · cites it 2× “Although it may sometimes aid in that inquiry, its principal function is to determine whether or not the hearsay exception is applicable.”
Buff v. State, 970 P.2d 564 (Nev. 1998). · cites it 6× “1991) (holding that a similar statement against interest implicating co-defendant and exculpating defendant was admissible under statute similar to NRS 51.345). Remaining allegations of error Pacheco also complains that it was error to: (1) admit the preliminary hearing…”
Lilly v. Virginia, 527 U.S. 116 (1999). “” Several States provide statutorily that their against-penal-interest hearsay exceptions do not allow the admission of “[a] statement or confession offered against the accused in a criminal case, made by a codefendant or other person implicating both himself and the accused.”
Fields v. State, 220 P.3d 709 (Nev. 2009). · cites it 2× “Nor did Grondona report her conversation with Rand to anyone until Grondona testified at the Fields trial.”
Carter v. State, 121 P.3d 592 (Nev. 2005). “28 See NRS 51.345. 29 See NRS 51.035(2)(a). 30 See NRS 51.”
Cirac v. Lander Cnty., 602 P.2d 1012 (Nev. 1979). · cites it 2× “See NRS 51.345. But the court acknowledged that in a divorce contest, the statement by itself would be a mere legal conclusion and that underlying facts relating to when the property was acquired would have to be found.”
Franco v. State, 866 P.2d 247 (Nev. 1993). · cites it 2× “2 The statement against interest exception, NRS 51.345, provides for the admissibility of [a] statement which at the time of its making: (a) Was so far contrary to the declarant’s pecuniary or proprietary interest; (b) So far tended to subject him to civil or criminal liability;…”
Sparks v. State, 759 P.2d 180 (Nev. 1988). · cites it 2× “Brown would also testify that on a separate occasion, when riding together in a car, Sparks coarsely boasted of having sex with his daughter since she was a little girl.”
Show all 38 citing cases →
— Nev. Rev. Stat. § 51.345(1) — 13 cases
State v. Bennett, 81 P.3d 1 (Nev. 2003). “The State cites NRS 51.345(1), which requires such circumstances for the admission of a "statement tending to expose the declarant to criminal liability and offered to exculpate the accused in a criminal case.”
Homick v. State, 825 P.2d 600 (Nev. 1992).
Buff v. State, 970 P.2d 564 (Nev. 1998). “1991) (holding that a similar statement against interest implicating co-defendant and exculpating defendant was admissible under statute similar to NRS 51.345). Remaining allegations of error Pacheco also complains that it was error to: (1) admit the preliminary hearing…”
Walker v. State, 6 P.3d 477 (Nev. 2000). “Pursuant to NRS 51.345, a statement against penal interest is admissible if: (1) at the time of its making, the statement tends to subject the declarant to civil or criminal liability; (2) a reasonable person in that position would not have made the statement unless he believed…”
Coleman v. State, 2014 NV 26 (Nev. 2014).
— Nev. Rev. Stat. § 51.345(1)(b) — 5 cases
Fields v. State, 220 P.3d 709 (Nev. 2009). “Nor did Grondona report her conversation with Rand to anyone until Grondona testified at the Fields trial.”
Buff v. State, 970 P.2d 564 (Nev. 1998). “1991) (holding that a similar statement against interest implicating co-defendant and exculpating defendant was admissible under statute similar to NRS 51.345). Remaining allegations of error Pacheco also complains that it was error to: (1) admit the preliminary hearing…”
Ford (Damien) v. State (Nev. 2019).
Ford (Damien) v. State (Nev. 2019).
Ford v. Bean (D. Nev. 2025).
— Nev. Rev. Stat. § 51.345(1)(d) — 1 case
Crockett v. State, 603 P.2d 1078 (Nev. 1979).
— Nev. Rev. Stat. § 51.345(2) — 1 case
Wood v. State, 990 P.2d 786 (Nev. 1999).
— Nev. Rev. Stat. § 51.345(l)(b) — 2 cases
Fields v. State, 220 P.3d 709 (Nev. 2009). “Nor did Grondona report her conversation with Rand to anyone until Grondona testified at the Fields trial.”
Buff v. State, 970 P.2d 564 (Nev. 1998). “1991) (holding that a similar statement against interest implicating co-defendant and exculpating defendant was admissible under statute similar to NRS 51.345). Remaining allegations of error Pacheco also complains that it was error to: (1) admit the preliminary hearing…”
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