If a statement is offered against a criminal defendant, the statement can qualify as a statement against interest for purposes of the federal hearsay exception for statements against interest even if there is no corroborating evidence of the trustworthiness of the statement.

United States v. Gulley, 526 F.3d 809, 817-818 (5th Cir. 2008) (upholding trial court's exclusion of victim's prior specific acts of violence because such evidence does not prove his alleged propensity for violence or that he was the first aggressor).When an exception makes the victim's character admissible, the testimony of a witness on direct examination about the victim's character must take the form of opinion or reputation and it cannot take the form of specific instances of victim's conduct.

Cf. United States v. Jackson, 335 F.3d 170, 179 (2d Cir. 2003) (upholding trial court's exclusion of Brown's plea allocution as residual hearsay exception because the statements "lacked corroborating circumstances....A statement not specifically covered by Federal Rule of Evidence 803 or 804 or by comparable State rules, but having equivalent circumstantial guarantees of trustworthiness, is not excluded by the hearsay rule, if the court determines that (A) the statement is offered as evidence of a material fact; (B) the statement is more probative on the point for which it is offered than any other evidence which the proponent can procure through reasonable efforts; and (C) the general purposes of these rules and the interests of justice will best be served by admission of the statement into evidence.

United States v. Miles, 290 F.3d 1341, 1351-1352 (11th Cir. 2002) (upholding trial court's admission of government witness's testimony as co-conspirator's statement because (1) "there was sufficient evidence in the record to....A statement falls within the hearsay exemption for statements of co-conspirators only if the statement was made in furtherance of the conspiracy.