J.T.J., A Child v. State
The Fourth DCA reversed a juvenile's probation revocation because the State's school attendance records were admitted as business records without the statutorily required advance written notice under section 90.803(6)(c), and no non-hearsay evidence corroborated the specific dates of the alleged violations. The court also found several curfew-violation findings unsupported because an allegation was withdrawn, no evidence was presented for one date, and testimony from a separate hearing on the same day could not be relied upon for another date. Because only one valid VOP finding (an unchallenged curfew violation) remained, the case was remanded for the trial court to determine if that single violation alone would support revocation.
Key facts
- A juvenile was charged with multiple violations of probation, including school attendance violations and curfew violations, based on school attendance records and testimony about alleged violation dates.
- The trial court admitted school attendance records as business records without providing the State's advance written notice required by statute, and revoked probation based on these records plus findings on several curfew violations.
- +2 more key facts with a free trial
Why it matters
This opinion reinforces that strict compliance with the business-records hearsay exception's notice requirement is mandatory in VOP proceedings, and that hearsay alone—even when technically admissible—cannot sustain a… — full analysis with a trial
Read the full opinion, holdings & search — free for 30 days
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision — in your hands.
- Search every tracked Florida decision in seconds
- Save, tag & file the cases that matter into your own library
- Read the full plain-English analysis and holdings
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.