Permissible forms of witness rehabilitation after impeachment by a showing or bias or interest

Fed. R. Evid. 405(a) advisory committee's note ("According to the great majority of cases, on cross-examination inquiry is allowable as to whether the reputation witness has heard of particular instances of conduct pertinent to the trait in question. Michelson v. United States, 335 U.S. 469, 69 S.Ct. 213, 93 L.Ed. 168 (1948); Annot., 47...Although a character witness who testifies to the reputation of another person or gives an opinion of the character of another person cannot testify to specific instances of that person's conduct to bolster the character witness's testimony, an opposing party may question the character witness about specific instances of the person's conduct to show that the character witness' testimony about the character of the person was not well-founded.

Tennessee v. Street, 471 U.S. 409, 413-414 (1985) (holding, in respondent's certiorari petition, that the trial court properly admitted the accomplice's out-of-court confession because it was introduced "to....The Sixth Amendment Confrontation Clause places no limits on the admission at trial of nonhearsay statements made prior to or outside of trial.

United States v. Peneaux, 432 F.3d 882, 892 (8th Cir. 2005) (upholding trial court's admission of the victim child's prior out-of-court statements pursuant to Rule 807 because "[t]he government provided the requisite....A statement is admissible under the hearsay exception created by Federal Rule of Evidence 807 or a comparable State rule only if circumstantial evidence shows that the affected statement is as trustworthy as the statements that are made admissible by the hearsay exceptions created by Federal Rules of Evidence 803 and 804 or by comparable State rules.