("[T]he exception for declarations against penal interest would seem to be 'firmly rooted.' "). 3 . In examining the totality of the circumstances, courts cannot rely on corroborating evidence to conclude that a hearsay statement is trustworthy for purposes of the Confrontation Clause. Wright, 497 U.S. at 822-823, 110 S.Ct. 3139. Moses correctly points out that the district court erred by relying on corroborating evidence in the instant case. See App. at 425. This error was harmless, however, given that the circumstances surrounding the making of Gaudelli's statements are alone sufficient to render them trustworthy. 4 .A review of the district court's order reveals that much of the grand jury testimony was admitted because it did not meet the definition of hearsay. See Supp.App. at 1-5 (<HOLDING>). Moses has not appealed this portion of the
holding that a text message constituted hearsay insofar as it was offered to prove the truth of the statement asserted holding that the admission of a report was not hearsay because it was not offered to prove its truth but to impeach the veracity of the witnesss direct testimony holding that some of the testimony is not being offered to prove the truth of the matter asserted and there fore is not hearsay holding that statements offered to establish defendants state of mind in making an employment decision and  not offered for the truth of the matter asserted are not hearsay holding testimony of officer explaining how officer came to suspect appellant was not objectionable as hearsay because it was not offered to prove the truth of the matter asserted but to show why the officer got an arrest warrant for and arrested appellant