Federal Rule of Evidence 410 or a comparable State rule bars the use of plea offers, plea negotiations, withdrawn pleas, and pleas of nolo contendere (no contest pleas) against the defendant who engaged in such plea negotiations, entered such a withdrawn plea, or entered such a plea of nolo contendere.

SEC v. Ficken, 546 F.3d 45, 53 (1st Cir. 2008) (holding, in plaintiff Commission's action against defendant broker for concealing his identity and that of his clients while trading shares of mutual funds,....The hearsay exceptions created by Federal Rule of Evidence 804 or a comparable State rule apply only if the declarant (the maker of the statement) is unavailable to testify at the trial or proceedings at which the declarant's statement is offered.

United States v. Gjerde, 110 F.3d 595, 603 (8th Cir. 1997) (upholding trial court's admission of the FBI agent's testimony [about Richard Field's description of Minnewaska] as a statement against interest because (1)....A statement falls within the federal hearsay exception for statements against interest only if the statement at the time of its making so far contrary to the declarant's pecuniary or proprietary interest, or so far tended to subject the declarant to civil or criminal liability, or to render invalid a claim by the declarant against another, that a reasonable person in the declarant's position would not have made the statement unless believing it to be true.

United States v. Quattrone, 441 F.3d 153, 191 (2d Cir. 2006) (upholding trial court's exclusion of "similar reinforcing emails" evidence because it was "insufficient to establish within the meaning of Federal Rule of Evidence 406 a habit of reflexively responding to subordinates' email suggestions.").If a pattern of behavior of a natural person does not rise to the status of a habit, it may constitute a character trait and such non-habitual behavior may be barred by the prohibition against circumstantial character evidence.