In the 1988 case of Beech Aircraft Corporation v. Rainey, the U.S. Supreme Court ruled that statements within a government report could be admitted as evidence in court if they were not conclusory in nature and met other requirements for admissibility under Federal Rule of Evidence 803(8)(C). The case arose from a wrongful death lawsuit filed by John C. Rainey against Beech Aircraft after his wife died in an airplane crash while piloting one of their planes. A Naval investigative report was submitted as evidence which contained opinions and conclusions about the cause of the crash, including potential design flaws with the aircraft's fuel system. The Supreme Court held that such factual findings are admissible even when they include evaluative or opinion-based conclusions, overturning previous rulings that had excluded such information.

In the dissenting opinion for Beech Aircraft Corporation v. Rainey, Justice Antonin Scalia disagreed with the majority's interpretation of Rule 803(8)(C) of the Federal Rules of Evidence. He argued that this rule should not allow factual findings from investigative reports to be admissible in court unless they are explicitly stated as such within a report’s conclusions or opinions. According to him, allowing all parts of an investigatory report into evidence would undermine cross-examination and give undue weight to hearsay statements contained in these reports. Furthermore, he contended that it was inconsistent with Congress' intent when drafting Rule 803(8)(C), which aimed at excluding raw data and subsidiary facts underlying expert opinions due to their potential unreliability if not subjected to adversarial testing.