either argument as a reason for reversal. 26 . There was no hearsay exception that would have permitted admission of Brisbon’s out-of-court statements as substantive evidence against Wonson. Brisbon’s statements implicating Wonson could not be introduced against Wonson as an admission because they were not made by or attributable to him, see Chaabi v. United States, 544 A.2d 1247, 1248 (D.C. 1988), nor were they admissible under the hearsay exception for statements against penal interest because they did not directly implicate the declarant, Brisbon. See Laumer v. United States, 409 A.2d 190, 199-200 (D.C. 1979) (en banc) (adopting the principles set forth in Federal Rule of Evidence 804(b)(3)); Williamson v. United States, 512 U.S. 594, 600-01, 114 S.Ct. 2431, 129 L.Ed.2d 476 (1994) (<HOLDING>). 27 . Only "in a certain, limited class of
holding that nonself inculpatory statements are not statements against penal interest under fedrevid 804b3 holding that statements made by a doctor to a patient are not admissible under fedrevid 8034 because the rule does not except statements by the person providing medical care holding that statements in proof of loss are not conclusive claimant could explain statements holding that only selfinculpatory aspects of hearsay statement but not other parts of statement are admissible under exception for statements against penal interest holding that exclusion of hearsay statements violated due process even though statements were not admissible under mississippi law which did not recognize declarations against penal interest as a exception to the rule against hearsay