Sims v. State
The First DCA affirmed revocation of Sims' probation for battery and burglary where the only direct evidence of his identity as the perpetrator came from the victim's hearsay statement to a deputy, but that statement was corroborated by substantial non-hearsay evidence (physical scene evidence, victim's demeanor/injuries, and the defendant's post-offense calls). The court clarified that under Russell v. State, non-hearsay evidence need not independently establish that the probationer committed the crime or directly link him to it—it need only corroborate the hearsay statement as a whole.
Key facts
- Sims was on probation for battery and burglary when the State sought to revoke his probation based on allegations that he committed a new battery and burglary offense.
- The only direct evidence of Sims' identity as the perpetrator came from the victim's hearsay statement to a deputy sheriff.
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Why it matters
This opinion resolves an intra-district tension by clarifying that Melton v. State does not impose a per se requirement of direct, non-hearsay evidence linking a probationer to a new offense, and that such a rule would… — full analysis with a trial
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