Does the prohibition against evidence of subsequent remedial measures apply to government-mandated remedial measures (such as involuntary product recalls)?

United States v. Washington, 498 F.3d 225, 230-232 (4th Cir. 2007) (upholding trial court's admission of testimony of expert based on statements of the machine operators about the forensic lab's diagnostic machine generated....The right of confrontation guaranteed by the Confrontation Clause of the Sixth Amendment to the U.S. Constitution puts no constraints on the admissibility of nontestimonial hearsay statements; the federal constitutional right of confrontation does not apply to such statements.

Christopher Phelps & Associates, LLC v. Galloway, 477 F.3d 128, 137 (4th Cir. 2007) (holding, in plaintiff architectural firm's action against defendant for copyright infringement, that the trial court properly admitted the Mecklenburg County....An exception to the hearsay rule applies to the following records of government offices and agencies: (A) public records that set forth the activities of the government office or agency; (B) public records that set forth observations that a government office or agency was required to make and report but this exception does not apply in criminal cases to observations of police officers and other law enforcement personnel; or (C) in civil actions and proceedings and in criminal cases when offered against the government, factual findings resulting from an investigation made pursuant to authority granted by law, unless the sources of information or other circumstances indicate the untrustworthiness of such findings.

Cf. United States v. Jones, 299 F.3d 103, 112-113 (2d Cir. 2002) (upholding trial court's admission of the testimony of Officer Moreland because "Chin's requirement that the [trial] court consider 'the....The right of confrontation guaranteed by the Sixth Amendment to the Constitution of the United States bars the introduction against a criminal defendant of testimonial hearsay by a nontestifying declarant unless (i) the absent declarant is unavailable to testify at trial and (ii) the defendant had an adequate opportunity to cross-examine the absent declarant prior to trial.