Are the divided federal appellate courts applying too stringent a standard when evaluating the admissibility of evidence under Federal Rule of Evidence 804 (b)(3), such that it undermines criminal defendants' constitutional right to present a complete defense?

Are the divided federal appel late courts applying too stringent a standard when ev aluating the admissibility of evidence under Federal Rule of Evidence 804 (b)(3) , such that it undermines criminal defendants ’ constitutional right to present a complete defense ?