statements of co-defendants that also implicate the defendant. See Lilly, 119 S.Ct. at 1897 (citing Bruton, 391 U.S. at 136, 88 S.Ct. 1620). Such statements are inherently unreliable because a co-defendant “often has a considerable interest in ‘confessing and betraying his co-criminals.’ ” Id. (quoting 5 Wigmore, Evidence § 1477, at 358 n. 1). The inculpatory statements of Gray and Clemons implicated only themselves, however, not Richardson. Therefore, they did not violate Bruton but fell within the “firmly rooted” hearsay exception for statements against penal interest. See Lilly, 119 S.Ct. at 1895. Accordingly, the admission of the challenged statements did not violate the Confrontation Clause. See White v. Illinois, 502 U.S. 346, 356, 112 S.Ct. 736, 116 L.Ed.2d 848 (1992) (<HOLDING>). 3. Closing Argument Richardson argues that
holding that statements within a firmly rooted hearsay exception do not violate the confrontation clause holding codefendants confession incriminating defendant was not within a firmly rooted exception to the hearsay rule under roberts standard holding that rule 8034 hearsay exception is firmly rooted for sixth amendment purposes holding coconspirator hearsay exception does not violate confrontation clause holding that the exception is not firmly rooted