In White v. Illinois, the United States Supreme Court expanded the scope of cases in which hearsay testimony is admissible without the defendant testifying. The Court concluded that the hearsay statements of a 4-year-old sexual assault victim were admissible despite failure to show the unavailability of the victim. This Note maintains that the decision in White v. Illinois presents a proper balance between the constitutional guarantees of the Confrontational Clause and the need for reliable testimony. The Note then argues that White is a valid extension of precedent, and concludes with an analysis of the rule proposed by Justices Thomas and Scalia in their concurrence. Footnotes