Quatermain v. United States

How later courts describe this case

• finding that a government employee’s statement did not meet any of the hearsay exceptions
• “Nothing in the Federal Rules of Evidence suggests an intention to alter the traditional [Santos ] rule and defendant has cited no truly contrary case indicating [a trend otherwise].”
• “This court has persistently refused to adopt [a per se rule against admissibility of polygraphs], choosing rather to leave the decision on admissibility to the sound discretion of the district court.”