This article discusses the reliability aspects of the co- conspiratory hearsay exception and discusses the vicarious admissions doctrine that has traditionally provided the foundation for the co-conspirator exception. The author notes that the conspiratorial relationship does not ensure reliability, that the requirements of the exemption do not screen out unreliable statements, and that conspirators can be trusted to speak truthfully when inaccuracy would thwart the objectives of their conspiracy. A revised rule should parallel the business records exception, which admits records kept in the regular course of business. Conspirator hearsay should never replace in-court testimony, but should be admitted only when courtroom confrontation of the declarant proves impossible. The article examines the procedural requirements for establishing the co-conspirator exception and discussing some the landmark court rulings in this area. 181 notes