A criminal defendant has a constitutional right, under some circumstances, to attack the credibility of adverse witnesses.

Tennessee v. Street, 471 U.S. 409, 413-414 (1985) (holding, in respondent's certiorari petition, that the trial court properly admitted the accomplice's out-of-court confession because it was introduced "to....The Sixth Amendment Confrontation Clause places no limits on the admission at trial of nonhearsay statements made prior to or outside of trial.

United States v. Williams, 989 F.2d 1061, 1068 (9th Cir. 1993) (upholding trial court's admission of witnesses' testimony [recounting statements made by defendant Williams and deceased adopted son, Mark Reitler concerning....If a statement is offered against a criminal defendant, it is uncertain whether the statement qualifies as a statement against interest for purposes of the federal hearsay exception for statements against interest only if there is corroborating evidence of the trustworthiness of the statement.

United States v. Alexander, 331 F.3d 116, 121-123 (D.C. Cir. 2003) (upholding trial court's admission of defendant girlfriend's 911 call as an excited utterance because even though "the intervening call might suggest that [the....A statement falls within the hearsay exception created by Federal Rule of Evidence 803(2) or a comparable State rule for excited utterances, only if the declarant (the maker of the statement) was under the stress of the startling event or condition when he or she made the statement that relates to that startling event or condition.