Jackson v. State, 207 Md. App. 336

Appellant TJ Sharocko Jackson was indicted in Prince George’s County for murder and related offenses from a 2008 home invasion; jury found him guilty on many charges and the court sentenced life plus ten years.
Before trial, the State moved to bar admission of co-defendant Jones’s signed statement to defense counsel, noting Jones would invoke Fifth Amendment; Jones claimed appellant was not present.
Jones’s eight-page handwritten statement, written by defense counsel and signed by Jones, claimed Jones acted with Darren Johnson, not Jackson, and that Jackson was absent.
The circuit court granted a motion in limine to exclude the statement as a declaration against penal interest under Rule 5-804(b)(3), finding lack of trustworthiness and corroboration.
The Court of Appeals reviewed Rule 5-804(b)(3) requirements—unavailability, against-penal-interest nature, and corroborating circumstances—and affirmed the exclusion
The judgment below affirmed, with costs borne by Jackson.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 5-804(b)(3) corroboration requirement was satisfied	State contends corroboration existed via surrounding circumstances	Jackson argues the statement was trustworthy and should be admitted	No; trial court’s corroboration finding was not clearly erroneous; exclusion affirmed

Gray v. State, 368 Md. 529 (Md. 2002) (declarations against penal interest require corroboration and trustworthiness)
Roebuck v. State, 148 Md.App. 563 (Md. App. 2002) (corroboration needed; assess content and declarant reliability)
Stewart v. State, 151 Md.App. 425 (Md. App. 2003) (corroboration and indicia of reliability are essential; discretion of trial court)
Cassidy v. State, 74 Md.App. 1 (Md. App. 1988) (trustworthiness standard for hearsay exceptions)
Matusky v. State, 343 Md. 467 (Md. 1996) (outlines trustworthiness and reliability analysis for 5-804(b)(3))