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Statements of arrested accomplices may be admitted only if they are “truly self-inculpatory, rather than merely attempts to shift blame or curry favor.”

Williamson v. United States, 512 U.S. 594, 601 (1994); (calling for careful scrutiny of statements that incriminate another).

804(b)(3); (quotation omitted).

12 as well as a federal case not binding on this court, for the assertion that the invocation of the right against self-incrimination can never have probative value.

But because it may be helpful on remand, we note that, under rule 804(b)(3), the supreme court has instructed courts to “consider whether each declaration or remark—rather than the narrative or conversation as a whole—is sufficiently against the 35 declarant’s interest.”

I Ozornia maintains that the prosecutor’s calling John to testify knowing he would refuse to answer questions constitutes reversible error based on the supreme court’s

substantive, non-hearsay evidence if (1) the declarant testified and is 3 “In State v. Dexter, we affirmed a district court’s ruling ‘barring the prosecution from impeaching one of its own witnesses with extrinsic evidence of prior inconsistent statement[s]’ because the State sought ‘to present, in the guise of impeachment, evidence which is not otherwise admissible.’ ” –57 (Minn. 2010) (quoting Dexter, d at 721).

(analyzing admissibility of purported Dexter evidence pursuant to the residual exception); -60 (Minn. 2010).

“Rule 801(d)(1) requires that a witness be testable about the statement, meaning that he must be reasonably responsive to questions on the circumstances in which he made it.” State v. Morales , (addressing a prior inconsistent statement introduced under ru le 801(d)(1)(A)).

State v. Morales , , 760 (Minn. 2010) (affirming a district court's ruling to not admit the recorded statements of a separately tried co-defendant under Rule 807 when the declarant had a strong motive to lie).

that a reasonable person in the declara nt’s position would not have made the statement unless believing it to be true.” (quoting Minn. R. Evid.

(“Courts in other jurisdictions agree that a defendant is unfairly prejudiced when a witness refuses to answer [by invoking the Fifth Amendment privilege], regardless of whether the witness was protected by a valid privilege.”).

“[When] the prosecution calls a witness for the purpose of prejudicing the defendant in the minds of the jury, knowing that the witness will claim immunity, reversible error results, regardless of actual prejudice.” (emphasis added) (quotation omitted).

d 737, 764-766 (Minn. 2010); review denied (Minn. Aug.

Houston’s does not convince us otherwise.

(concluding that inculpatory statements to friend were nontestimonial); (holding that statement made unwittingly to government informant is nontesti-monial).