Stephon Lavelle Walter, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals reversed the trial court's admission of the co-defendant's out-of-court statements and remanded for a harm analysis. It held that under Texas Rule of Evidence 803(24) only statements directly against the declarant's penal interest, including blame‑sharing remarks, are admissible, while blame‑shifting statements are excluded. The Court also concluded that the statements were non‑testimonial and therefore did not violate the Confrontation Clause. Justice Hervey dissented, arguing that blame‑shifting statements supported by corroborating circumstances should be admissible.