Expressions of apology or sympathy as evidence of fault, guilt, or liability in any subsequent civil or criminal action.

United States v. Jinadu, 98 F.3d 239, 246 (6th Cir. 1996) (upholding trial court's admission of agent's testimony [about defendant's confession to another agent] as statement against defendant Lawal's penal interest....A statement qualifies as a statement against interest for purposes of the hearsay exception for statements against interest only if the statement, at the time the declarant made it, was so contrary to the declarant's interest that a reasonable person in the declarant's position would not have made if the declarant had believed the statement to be untrue.

Schmidt v. City of Bella Villa, 557 F.3d 564, 570 (8th Cir. 2009) ("'[U]nder the Rules the trial judge must ensure that any and all scientific testimony or evidence admitted is not only relevant, but reliable.' [Daubert], 509 U.S. at 589, 113 S.Ct. 2786; see also Kumho Tire Co. v. Carmichael, 526 U.S....Expert, scientific, or specialized evidence satisfies the requirements under Federal Rule of Evidence 702 or similar rules for the admissibility of expert, scientific, or specialized evidence, only if the expert, scientific, or specialized field or method is shown to be reliable. "Reliability" for this purpose is more than bare relevance but the expert evidence does not have to satisfy the burden of proof applicable to the fact for which the expert, scientific, or specialized evidence is offered.

Nowell v. Universal Electric Co., 792 F.2d 1310, 1314-1315 (5th Cir. 1986) (holding, in plaintiff wife's action against defendant electric company for wrongful death, that the trial court erroneously admitted the testimony [about an....The hearsay exception created by Federal Rule of Evidence 807 or a comparable State rule applies only if the the affected statement is evidence of a material fact.