codefendant

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“Not only were the incriminating portions of Mark Lilly’s confession not a declaration against penal interest, but these statements were part of a custodial confession of the sort that this Court has viewed with ‘special suspicion’ given a codefendant’s ‘strong motivation to implicate the defendant and to exonerate himself.’” J. Stevens, Lilly v. Virginia, 527 U.S. 116, 146 (1999).