a firmly rooted hearsay exception, or by the presence of particularized guarantees of trustworthiness, such that adversarial testing would be expected to add little, if anything, to the statement’s reliability. 448 U.S. at 66, 100 S.Ct. 2531. This standard was applied in several subsequent noteworthy decisions. See, e.g., Lee v. Illinois, 476 U.S. 530, 545-46, 106 S.Ct. 2056, 90 L.Ed.2d 514 (1986) (concluding “a co-defendant’s confession inculpating the accused is inherently unreliable” and rejecting State’s “interlocking confessions” argument, holding instead “when the discrepancies between the statements are not insignificant, the co-defendant’s confession may not be admitted”); see also Lilly v. Virginia, 527 U.S. 116, 134, 119 S.Ct. 1887, 144 L.Ed.2d 117 (1999) (plurality opinion) (<HOLDING>); Idaho v. Wright, 497 U.S. 805, 820-21, 110
holding codefendants confession incriminating defendant was not within a firmly rooted exception to the hearsay rule under roberts standard holding that victims statements were hearsay admissible under the state of mind exception to the hearsay rule and constitutionally permissible under ohio v roberts citations omitted holding that statements within a firmly rooted hearsay exception do not violate the confrontation clause holding that rule 8034 hearsay exception is firmly rooted for sixth amendment purposes holding that the exception is not firmly rooted