Although the Sixth Amendment right of confrontation is a constraint on the admissibility of inculpatory evidence against a defendant at a criminal trial, the Confrontation Right also guarantees a criminal defendant some means for confronting, challenging, and cross-examining witnesses who testify against him and her. The Sixth Amendment's Confrontation Clause confers on a criminal defendant the right to elicit from an important adverse witness facts -- particularly facts that suggest bias and interest -- that are likely to be significantly probative of the credibility of the testimony of the adverse witness about material facts in issue.

Cf. United States v. Macey, 8 F.3d 462, 467-468 (7th Cir. 1993) (upholding trial court's exclusion of office manager's testimony [about defendant's statements that he never intended the invoice to be fraudulent and that he....To fall within the hearsay exception created by Federal Rule of Evidence 803(3) or a comparable State rule for person's present internal states, a statement by the declarant (the maker of the statement) must be contemporaneous with the mental state or event sought to be proven.

Cf. United States v. Nguyen, 465 F.3d 1128, 1131-1132 (9th Cir. 2006) (reversing conviction for willful failure to comply with the terms of a release under supervision agreement because the trial court erred in admitting into....There is a hearsay exception for evidence of a final judgment, entered after a trial or upon a plea of guilty (but not upon a plea of nolo contendere), adjudging a person guilty of a crime punishable by death or imprisonment in excess of one year, to prove any fact essential to sustain the judgment, but not including, when offered by the Government in a criminal prosecution for purposes other than impeachment, judgments against persons other than the accused.

United States v. Daly, 716 F.2d 1499, 1510 (9th Cir. 1983) (upholding trial court's admission of co-defendant's testimony "that she and Criswell went to [accused's] car lot, where she received a car known by Criswell and Ginger to be stolen"where it constituted as circumstantial evidence of accused Daly's...Evidence of a criminal or wrongful act apart from the act that at issue at trial Is not barred by the prohibition against circumstantial use of character if intent, knowledge, mistake, or accident is a legally-material factual issue, the opposing party suggests the non-existence of knowledge or urges mistake or accident as a defense, and evidence of another crime, wrong, or act is offered to prove the knowledge or the absence of mistake or accident by a criminal defendant or other person.