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We have characterized the right to confrontation as “one of the basic safeguards of liberty.” State v. Cook, 135 N.H. 655, 661 (1992).

[¶20] We have likewise characterized the right to confrontation as “one of the basic safeguards of liberty.” State v. Cook, 135 N.H. 655, 661 (1992) (quotation omitted).

State v. Cook, 135 N.H. 655, 664 (1992) (reasoning that a declarant who speaks spontaneously “presumably does not have sufficient time to contrive a false version of events”).

a statement of which the party has manifested adoption or belief in its truth.” This exception includes the adoptive or tacit admission doctrine, State v. Cook, 135 N.H. 655, 663 (1992), upon which the trial court relied in admitting evidence of the defendant’s silence in this case.

Regarding the defendant’s State constitutional claims, we have traditionally applied Roberts to Confrontation Clause challenges under the State Constitution.

Hearsay statements ordinarily do not violate a defendant’s right to confront witnesses so long as they bear “particularized guarantees of trustworthiness,” State v. Cook, 135 N.H. 655, 662 (1992), or fall within a “firmly rooted hearsay exception.” State v. Bader, 148 N.H. 265, 277 (2002); but see State v. Christiansen, 135 N.H. 583, 586 (1992) (blood test report admitted without live testimony constitutes “trial by certificate and affidavit” and violates Confrontation Clause).

Reliability can be inferred without more in a case where the evidence falls within a firmly rooted hearsay exception.” Idaho v. Wright, 497 U.S. 805, 814-15 (1990) (quotations omitted; emphasis added); see State v. Cook, 135 N.H. 655, 667-68 (1992) (Thayer, J., concurring specially).

State v. Cook, 135 N.H. 655, 660-61 (1992); Fendler v. Goldsmith, 728 F.2d 1181, 1188 (9th Cir. 1984).

State v. Cook, 135 N.H. 655, 660, 610 A.2d 800, 803 (1992) (recognizing “that evidence admitted under a state-created exception to the hearsay rule may nevertheless infringe constitutional rights”).

Information pertaining to a witness’s mental stability may be relevant to credibility, see State v. Cook, 135 N.H. 655, 663-65, 610 A.2d 800, 805-07 (1992) (recognizing that mental stability may be relevant to credibility of witness), and therefore useful as impeachment evidence at trial, see Bagley, 473 U.S. at 676 (rejecting distinction between impeachment evidence and exculpatory evidence); Laurie, 139 N.H. at 330-32, 653 A.2d at

We will sustain the trial court’s decision unless its conclusion is clearly unreasonable.

See, e.g., State v. Cook, 135 N.H. 655, 661, 610 A.2d 800, 804 (1992) (right to confront witnesses); State v. Briand, 130 N.H. 650, 657, 547 A.2d 235, 240 (1988) (right against self-incrimination).

We analyze the constitutional question first because we assume that the constitutional requirement that there be “particularized guarantees of trustworthiness,” State v. Cook, 135 N.H. 655, 662, 610 A.2d 800, 802 (1992) (quotation omitted), is more rigorous than the requirement in New Hampshire Rule of Evidence 803(4) that there be “circumstances indicating” the “trustworthiness” of the hearsay statements.

Susan was eventually charged with and convicted of conspiracy and accomplice to murder for her involvement.