Confessional statements made to undercover police operatives posing as criminal gang members are not made to 'persons in authority' and are admissible provided they are voluntary and not excluded under the unfairness or public policy discretions. Inherent unreliability is not a separate standalone basis for discretionary exclusion of confessional evidence; rather, possible unreliability is relevant as a consideration within the unfairness discretion. The reliability of a voluntarily made and otherwise admissible self-inculpatory statement is almost invariably for the jury to decide.
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