D.D.R. v. State
The Second DCA reversed a juvenile disposition order revoking D.D.R.'s probation for a curfew violation because the State's case rested almost entirely on hearsay testimony from probation and case-management witnesses who did not personally observe the violations. The one nonhearsay witness's testimony was too vague to establish a curfew violation on any of the specific dates alleged in the VOP petition, and D.D.R.'s own ambiguous admission likewise failed to tie a violation to the charged dates.
Key facts
- D.D.R., a juvenile, was charged in a violation of probation (VOP) petition with curfew violations alleged to have occurred on nineteen specific dates.
- The State's case relied almost entirely on hearsay testimony from probation and case-management witnesses who did not personally observe the alleged violations, with only one nonhearsay witness providing vague testimony about seeing the juvenile leave home in the afternoon and being absent the next morning.
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Why it matters
This opinion reinforces and applies the well-established rule that hearsay alone cannot sustain a probation or VOP revocation, requiring practitioners to scrutinize whether any live, nonhearsay witness actually observed… — full analysis with a trial
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