AD4: Crawford v Washington not applicable at probation violation hearing

People v Brown, 2006 NY Slip Op 06706 [available here]

In another less-than-surprising decision, the Fourth Department confirms that the testimonial hearsay rule promulgated by the Supreme Court in Crawford v Washington (based on the Confrontation Clause) does not apply at any proceeding other than a full criminal trial; in this case a probation revocation hearing. (Brown, 2006 NY Slip Op 06706.) As I noted here, the Supreme Court telegraphed as much in Crawford.