In civil cases, Rule 804(b)(1) of the Federal Rules of Evidence permit the proponent to offer former testimony against a party to the prior proceeding, or against a party whose 'predecessor in interest' had an opportunity and similar motive to examine the witness in the prior proceeding. The legislative history of the rule indicates that it should parallel the use of prior-action depositions under Rule 32 of the Federal Rules of Civil Procedure. Courts generally ignore the predecessor in interest requirement, however, relying instead on the fact that the prior witness was under oath and was cross-examined under circumstances relevant to the present case. A more appropriate approach would be to admit former testimony against a party who was not a party to the prior proceeding only if the party and the predecessor in interest have a sufficiently close relationship. 225 footnotes.