The exclusion of relevant exculpatory evidence offered by a defendant in a trial does not violate a defendant's right to due process or compulsory process or to a defendant's constitutional right to present a defense if exclusion of such exculpatory evidence is not an arbitrary or disproportionate remedy.

United States v. Jones, 299 F.3d 103, 112-113 (2d Cir. 2002) (upholding trial court's admission of the hearsay testimony of Officer Moreland about the statements of the declarants because "the statements made by the....Federal Rule of Evidence 803(1) and comparable State rules create a hearsay exception for a statement setting forth the declarant's perception of an event or condition at the time the declarant makes the statement or immediately thereafter.

Cf. United States v. Jackson, 335 F.3d 170, 179 (2d Cir. 2003) (upholding trial court's exclusion of Brown's plea allocution as residual hearsay exception because the statements "lacked corroborating circumstances....A statement not specifically covered by Federal Rule of Evidence 803 or 804 or by comparable State rules, but having equivalent circumstantial guarantees of trustworthiness, is not excluded by the hearsay rule, if the court determines that (A) the statement is offered as evidence of a material fact; (B) the statement is more probative on the point for which it is offered than any other evidence which the proponent can procure through reasonable efforts; and (C) the general purposes of these rules and the interests of justice will best be served by admission of the statement into evidence.

United States v. Cash, 394 F.3d 560, 564 (7th Cir. 2005) (upholding trial court's admission of federal employee's testimony [wherein the witness read directly from the Form 119 reports] as an exception to the hearsay....Federal Rule of Evidence 803(5) or a comparable State rule creates a hearsay exception for a memorandum or record concerning a matter about which a witness once had knowledge but now has insufficient recollection to enable the witness to testify fully and accurately, shown to have been made or adopted by the witness when the matter was fresh in the witness' memory and to reflect that knowledge correctly.