United States v. Saada
United States Court of Appeals for the Third Circuit
212 F.3d 210 (3d Cir. 2000)
The Saadas (defendants) were charged with insurance fraud after allegedly staging a warehouse flood, and at trial they introduced a deceased employee's statement, admitted as an excited utterance, supporting their claim the flooding was accidental. To impeach that hearsay declarant, the prosecution asked the court to take judicial notice of two state supreme court decisions removing him from the bench and disbarring him for unethical conduct, which the district court did; the Saadas were convicted and appealed that ruling.
Whether the rule barring extrinsic evidence of a witness's prior bad acts to impeach character for truthfulness applies equally when the impeachment target is an unavailable hearsay declarant rather than a live witness.