Reyes v. State

SULLIVAN, Justice.

Courts have adopted two principal methods for determining the admissibility of hearsay evidence in probation revocation hearings: a “balancing test” that weighs the probationer’s interest in confronting the declarant against the State’s interest in not producing same; and a “substantial trustworthiness test” that determines the reliability of the evidence. For the reasons set forth in this decision, we adopt the substantial trustworthiness test.

Background

In 1998, a jury found Defendant George Reyes guilty of aggravated battery. Reyes’s original sentence was corrected in…