Whether the requirement of relevance for admissibility applies only to circumstantial evidence or whether it also appllies to supposedly non-circumstantial evidence such as tangible evidence or direct evidence.

Cf. United States v. Pena-Gutierrez, 222 F.3d 1080, 1085-1086 (9th Cir. 2000) (holding that the defendant's rights under the Compulsory Process Clause of the Sixth Amendment and the Due Process Clause of the Fifth Amendment were not....The prohibition, grounded in the Compulsory Process Clause, against deliberate government action that deprives a criminal defendant of the relevant and material exculpatory testimony of a witness may effectively limit the government's use of hearsay evidence against a criminal defendant.

United States v. $125,938.62 Proceeds of Certificates of Deposit, 537 F.3d 1287, 1292 (11th Cir. 2008) (holding, in government's civil forfeiture action involving funds stolen from the Nicaraguan treasury, that evidence of Nicaraguan President's judgment of....There is a hearsay exception for evidence of a final judgment, entered after a trial or upon a plea of guilty (but not upon a plea of nolo contendere), adjudging a person guilty of a crime punishable by death or imprisonment in excess of one year, to prove any fact essential to sustain the judgment, but not including, when offered by the Government in a criminal prosecution for purposes other than impeachment, judgments against persons other than the accused.

17 U.S.C. § 410(c) (A sealed certificate of copyright registration is prima facie evidence of the facts stated in it.).Federal Rule of Evidence of 902(10) and comparable State rules provide that any signature, document, or other matter is self-authenticating -- i.e., requires no further evidence of authenticity to be admissible in evidence -- if an applicable statute provides that the signature, document, or other matter is presumptively authentic or if an applicable statute provides that the signature, document, or other matter is prima facie evidence of its own authenticity.