context: P 39 As noted, Best is consistent with decisions of other courts that have scrutinized and severely criticized Oates.
citation_a.signal: see also
citation_a.identifier: 778 F.2d 1195, 1202
citation_a.parenthetical: "[W]e now join the Second, Ninth and Eleventh Circuits in [refusing to apply] the restriction [in Oates ]."
citation_a.sentence: See United States v. Wilmer, 799 F.2d 495, 500-01 (9th Cir.1986) (expressly rejecting the Oates court’s reasoning and concluding “calibration certificate was admissible under Rule 803(8)(B)” because “the exclusionary provisions of [that rule] were intended to apply to observations made by law enforcement officials at the scene of a crime or the apprehension of the accused and not ‘records of routine, nonadversarial matters’ made in a nonadversarial setting”), quoting United States v. Orozco, 590 F.2d 789, 793 (9th Cir. 1979); see also United States v. Hayes, 861 F.2d 1225, 1229 (10th Cir.1989) (“Oates has been criticized by both courts and commentators as an unduly broad interpretation of Rule 803(8).”); United States v. Metzger, 778 F.2d 1195, 1202 (6th Cir.1985) (“[W]e now join the Second, Ninth and Eleventh Circuits in [refusing to apply] the restriction [in Oates ].”) “
citation_b.signal: see
citation_b.identifier: 590 F.2d 789, 793
citation_b.parenthetical: expressly rejecting the Oates court's reasoning and concluding "calibration certificate was admissible under Rule 803(8
citation_b.sentence: See United States v. Wilmer, 799 F.2d 495, 500-01 (9th Cir.1986) (expressly rejecting the Oates court’s reasoning and concluding “calibration certificate was admissible under Rule 803(8)(B)” because “the exclusionary provisions of [that rule] were intended to apply to observations made by law enforcement officials at the scene of a crime or the apprehension of the accused and not ‘records of routine, nonadversarial matters’ made in a nonadversarial setting”), quoting United States v. Orozco, 590 F.2d 789, 793 (9th Cir. 1979); see also United States v. Hayes, 861 F.2d 1225, 1229 (10th Cir.1989) (“Oates has been criticized by both courts and commentators as an unduly broad interpretation of Rule 803(8).”); United States v. Metzger, 778 F.2d 1195, 1202 (6th Cir.1985) (“[W]e now join the Second, Ninth and Eleventh Circuits in [refusing to apply] the restriction [in Oates ].”) “