The federal constitutional guarantee of due process may limit the government's right to introduce unreliable hearsay evidence against a defendant in a criminal trial.

United States v. Fujii, 301 F.3d 535, 539 (7th Cir. 2002) (upholding trial court's admission into evidence of the check-in and reservation records as business records because they "were compiled and maintained in....Document must have been prepared in the normal course of business.

Victor v. Nebraska, 511 U.S. 1, 5-17 (1994) (jury instructions that used "proof to a moral certainty" and "moral evidence" were, under the circumstances, not improper; the Court adds: "We are somewhat more concerned with Sandoval's argument that the phrase 'moral certainty' has lost its historical...Some courts have approved and some courts have criticized jury instructions saying that proof beyond a reasonable doubt is proof of guilt to a moral certainty.

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.