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United States v. Alvarez, 584 F.2d 694, 701 (5th Cir. 1978) (reversing conviction for heroin trafficking because the trial court erroneously admitted principal witness's in-court testimony of the out-of-court statements....If a statement is offered against a criminal defendant, the statement qualifies as a statement against interest for purposes of the federal hearsay exception for statements against interest only if there is corroborating evidence of the trustworthiness of the statement.

Fed. R. Evid. 609(b) ("Time limit. Evidence of a conviction under this rule is not admissible if a period of more than ten years has elapsed since the date of the conviction or of....Under federal law the conviction of a witness is generally inadmissible to impeach the witness if more than ten years has elapsed since the conviction or since the release of the witness from imprisonment for that conviction, whichever is later.

United States v. Higgs, 353 F.3d 281, 310 (4th Cir. 2003) (upholding trial court's admission of defendant's silence as an admission under Rule 801(d)(2)(B) because "the district court appropriately allowed the jury....An adoptive admission is exempt from the prohibition against hearsay evidence.