Admissibility requirements for out-of-court statements are reviewed with the conclusion that such statements must meet the requirements of the hearsay exception and the Confrontation Clause to be admissible in criminal court. California v. Green (1970), Dutton v. Evans (1970), and Ohio v. Roberts (1980) affirmed that the Confrontation Clause requires that unavailable witnesses' statements must bear sufficient indicia of reliability to be used. A proposed hearsay exception is delineated, in accordance with the finding of these cases, which calls for hearsay statements to be found sufficiently trustworthy and adequately corroborated to ensure due process. A discussion of alternatives to face-to-face confrontation (such as a child's courtroom in which jury, judge, and defendant see the witness but the witness cannot see the defendant: closed-circuit testimony, and videotaped depositions) finds these alternatives to be unconstitutional. Statutes regarding unavailability and potential severe psychological injury to child witnesses, the use of closed-circuit television and a child's courtroom when witnesses are unavailable, and videotaping depositions should be amended. New hearsay exceptions and new video technological procedures must comply with the Confrontation Clause. 13 cases citations and a listing of 25 other cases.