The right of confrontation guaranteed by the Confrontation Clause of the Sixth Amendment to the U.S. Constitution puts no constraints on the admissibility of nontestimonial hearsay statements; the federal constitutional right of confrontation does not apply to such statements.

Vincent v. Louis Marx & Co., 874 F.2d 36, 42 (1st Cir. 1989) (holding, in plaintiff injured party's product liability action against defendant manufacturer, that the exclusion of the evidence of the settlement amount in....Settlement offers and statements made during settlement negotiations are inadmissible if such offers and statements are offered to (i) show the validity or invalidity of a claim when the validity of the claim is in dispute, (ii) show the amount of damages when the amount of the claim is in dispute, or (iii) to impeach a witness by showing a prior inconsistent statement or specific contradiction.

Montana v. Egelhoff, 518 U.S. 37, pin? (1996) (Scalia, J., for plurality of four: "[T]he proposition that the Due Process Clause guarantees the right to introduce all relevant evidence is simply indefensible" and "Of course, to say that the right to introduce relevant evidence...The right to due process guaranteed by the Fifth and Fourteenth Amendments prohibits the exclusion of probative exculpatory evidence in criminal trials when exclusion of such evidence is unreasonable, arbitrary, or disproportionate.

United States v. Malpica-Garcia, 489 F.3d 393, 396 (1st Cir. 2007) (upholding trial court's admission of testimony given by government witness which did not violate defendant's rights under the Confrontation Clause because....The Sixth Amendment Confrontation Clause places no limits on the admission at trial of nonhearsay statements made prior to or outside of trial.