Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice. Don't rely. Quick work.
First Circuit: US v. Lee
Out of court statements not subject to the Confrontation Clause and hearsay scrutiny had sufficient indicia of reliability to establish the drug quantities used at sentencing.