State v. Young
574 P.2d 1171, 89 Wash. 2d 613, 1978 Wash. LEXIS 1352 (1978)
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Rule of Law:
An out-of-court declaration by a third party against their penal interest is admissible as an exception to the hearsay rule only if the proponent of the statement can demonstrate that it meets strict criteria establishing a high probability of trustworthiness, including the unavailability of the declarant and the presence of significant corroborating circumstances.
Facts:
- In 1972, Judge James J. Lawless sentenced Ricky A. Young for second-degree burglary, imposing a one-year jail term and an order prohibiting contact with a 16-year-old girl whom Young later married.
- A few weeks before the bombing, Young was charged with two new felonies, which triggered a hearing for the potential revocation of his prior suspended sentence.
- Young's probation officer informed him that Judge Lawless would preside over the revocation hearing.
- Young expressed that he did not believe he could get a 'fair shake' from Judge Lawless and filed affidavits of prejudice against the judge in his pending felony cases.
- On June 3, 1974, a pipe bomb mailed in a package exploded in Judge Lawless's chambers, causing his death.
- Investigators reconstructed the bomb and found a letter inside the mailing wrapper which contained two latent fingerprints.
- One of the fingerprints on the letter was positively identified as belonging to Young's right thumb.
- After his arrest, Young made several inculpatory statements to postal inspectors and later confessed to his cellmate, David McKinney, that he built and mailed the bomb to retaliate against Judge Lawless.
Procedural Posture:
- On August 6, 1974, defendant Ricky A. Young was arrested on federal charges of mailing a nonmailable explosive.
- On August 7, 1974, the State of Washington filed a first-degree murder charge against Young.
- Young's motion for a change of venue from Benton County was granted, and the trial was moved to Spokane County.
- The first trial, held in December 1974, ended in a mistrial after the jury was unable to reach a verdict.
- A retrial in July 1975 resulted in a jury convicting Young of first-degree murder.
- Young (appellant) appealed the conviction to the Supreme Court of Washington.
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Issue:
Does the exclusion of anonymous letters and a third party's uncorroborated out-of-court statement confessing to a crime violate a defendant's due process rights when the statements lack sufficient corroborating circumstances to indicate a high probability of trustworthiness?
Opinions:
Majority - Brachtenbach, J.
No. The exclusion of the anonymous letters and the third party's statement does not violate the defendant's due process rights because the evidence failed to meet the necessary criteria for admissibility. To be admissible as an exception to the hearsay rule, a third party's declaration against penal interest must be accompanied by corroborating circumstances that clearly indicate a high probability of trustworthiness. The court adopted the four-part test from State v. Gardner, requiring that (1) the declarant is unavailable, (2) the declaration admits an unlawful act, (3) the declaration is inconsistent with the defendant's guilt, and (4) there are clear corroborating circumstances indicating trustworthiness. Here, the anonymous letters from 'The People's Army' were properly excluded because the declarant was unidentifiable and there was no corroboration. Similarly, the alleged statement by Brent Pursell was inadmissible because the defense failed to show he was unavailable to testify and offered no corroborating evidence to establish the statement's trustworthiness, which is a standard required by Chambers v. Mississippi.
Analysis:
This case establishes a clear and demanding standard in Washington for the admission of third-party declarations against penal interest, effectively codifying the principles from the U.S. Supreme Court's decision in Chambers v. Mississippi. By adopting the four-part Gardner test, the court balances a defendant's due process right to present a defense with the evidentiary need for reliability. This ruling creates a high threshold for defendants seeking to introduce exculpatory hearsay, requiring them to provide substantial corroboration to prevent the jury from being misled by untrustworthy or fabricated confessions. It reinforces the principle that constitutional rights do not override established evidentiary rules unless the excluded evidence possesses significant indicia of reliability.
