Santiago v. O'BRIEN, 628 F.3d 30

Santiago was tried in Massachusetts for trafficking cocaine found in his apartment after a 1997 police raid.
Santiago claimed the drugs and paraphernalia belonged to Oley Saradeth, an acquaintance who stayed at his apartment and died before trial.
Santiago testified the drugs were Oley's, attempting to shift blame; a purported December 1997 confession by Oley to his brother was proffered but excluded as hearsay.
At a voir dire, Fanta Saradeth testified about the private confession and an April 1998 apology; both were excluded by the trial court.
Santiago was convicted and sentenced to 15 years; state appellate courts affirmed, and the Massachusetts Supreme Judicial Court denied review.
Santiago then sought federal habeas relief alleging a Sixth Amendment violation from the exclusion of the exculpatory testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did excluding Oley's confession violate the Sixth Amendment?	Santiago asserts the exclusion deprived him of a key exculpatory witness.	Oley's statements were not trustworthy or properly admissible as against penal interest under state law.	No constitutional error; state ruling reasonable under due process and reliability standards.
Was the state court's application of the Massachusetts penal-interest rule reasonable under federal due process?	The private confession should be admissible as exculpatory against penal interest.	The declaration to a brother, private and uncorroborated, was not sufficiently against penal interest or trustworthy.	Yes; the state court properly applied the rule and did not violate due process.
Would the alleged error be reversible under the harmless error standard?	Exclusion could have influenced the verdict in light of the exculpatory value.	The strong independent evidence tied to Santiago's guilt lessens any potential prejudice.	Prejudice not shown; impact on the verdict was not substantial.

Chambers v. Mississippi, 410 U.S. 284 (U.S. 1973) (due process and fairness when essential exculpatory evidence is excluded)
Scheffer v. United States, 523 U.S. 303 (U.S. 1998) (not every exclusion of hearsay violates the Sixth Amendment)
Montana v. Egelhoff, 518 U.S. 37 (U.S. 1996) (limits on interpreting rules for mental state in evidentiary context)
United States v. Millan, 230 F.3d 431 (1st Cir. 2000) (considerations of reliability and trustworthiness in evidence)
Commonwealth v. Drew, 397 Mass. 65 (Mass. 1986) (requirements for statements against penal interest)
Commonwealth v. Carr, 373 Mass. 617 (Mass. 1977) (conditions for admissibility of statements against penal interest)
United States v. Barrett, 539 F.2d 244 (1st Cir. 1976) (private statements and exceptions to hearsay rules)