Reyes v. State

BARNES, Judge,

concurring in result.

I concur in the result reached by the majority. However, I respectfully disagree with the way in which it reached that result. I believe that requiring the State to demonstrate the practical unavailability of a witness before being permitted to introduce reliable hearsay evidence during a probation revocation hearing is unnecessarily burdensome.

In my view, the Seventh Circuit has correctly concluded that if the State seeks to introduce substantially reliable hearsay during a probation revocation hearing, there is no need to additionally demonstrate that it would be impracticable to obtain the witness’ presence at the hearing. See Kelley, 446 F.3d at 692.7 As the majority notes, Morrissey holds that probationers or parolees facing revocation have a due process right “to confront and cross-examine adverse witnesses (unless the hearing officer specifically finds good cause for not allowing confrontation).... ” Morrissey, 408 U.S. at 489, 92 S.Ct. 2593. The Supreme Court, however, did not define the meaning of “good cause.” It did state that the probation or parole revocation process “should be flexible enough to consider evidence including letters, affidavits, and other material that would not be admissible in an adversary criminal trial.” Id.

The Seventh Circuit, as well as the Fourth, Tenth, and District of Columbia Circuits, “essentially treats a finding of ‘substantial trustworthiness’ as the equivalent of a good cause finding for the admission of hearsay in the revocation context.” Kelley, 446 F.3d at 692. I believe our supreme court has at least tacitly approved of this approach to the admission of hearsay evidence in probation revocation and other similar hearings. In Cox, as the majority notes, the court said it was unnecessary to adopt either the balancing approach or the substantial reliability approach to admitting hearsay during revocation hearings. See Cox, 706 N.E.2d at 550 n. 8. On the other hand, the court did state, “After a careful review of the record, we find that the trial court accorded Defendant his rights under the Due Process Clause-” Id. at 550. The court also said, “we hold that in probation and community corrections placement revocation hearings, judges may consider any relevant evidence bearing some substantial in-dicia of reliability. This includes reliable hearsay.” Id. at 551 (footnote omitted). Although the Cox court obviously was aware that probationers facing revocation are entitled to certain due process rights, it placed no limitation on the use of hearsay in probation revocation hearings, aside from a showing of reliability.

The Cox court also expounded upon the need for flexibility in probation revocation procedures:

[Flexibility] is necessary to permit the court to exercise its inherent power to enforce obedience to its lawful orders.
There are also sound policy justifications for such flexibility. Alternative sentences such as probation and community corrections serve the humane pur*1286poses of avoiding incarceration and of permitting the offender to meet the offender’s financial obligations. But for sentencing alternatives to be viable options for Indiana judges, judges must have the ability to move with alacrity to protect public safety when adjudicated offenders violate the conditions of their sentences. Put differently, obstacles to revoking an alternative sentence may diminish the likelihood of community corrections placements being made in the first place.

Id. at 550.

I agree wholeheartedly with these observations. I would also note that probation revocation hearings are common, occurring probably thousands of times a year in Indiana. Requiring the State to either procure a live witness or establish his or her practical unavailability, even though the State is able to produce a substantially reliable hearsay statement of the witness, has the possibility to create significant impediments to the State or a trial court moving “with alacrity” to address alleged probation violations committed by an already-convicted offender. The majority here notes the State sufficiently demonstrated that it would have been burdensome to produce Retz as a witness, because the lab he worked at has performed thousands of drugs screens and because it was located approximately 130 miles from the trial court. Even if the lab had been next door to the courthouse, however, Retz should not be expected to spend his valuable time attending probation revocation hearings to give live testimony that merely duplicates an already demonstrably reliable hearsay statement.

I fully agree with the majority’s analysis regarding the substantial reliability of Retz’s hearsay statements regarding the timing of Reyes’s cocaine use. On that basis alone, I would affirm that Retz’s statements were properly considered by the trial court and formed a sufficient evi-dentiary basis for the revocation of Reyes’s probation.

. Kelley also holds that Crawford v. Washington, 541 U.S. 36, 124 S.Ct. 1354, 158 L.Ed.2d 177 (2004), which limited the use of hearsay in criminal prosecutions, does not apply to probation revocation hearings. See Kelley, 446 F.3d at 689.