Oregon v. Martin
Annotate this CaseDefendant Deangelo Martin argued his due process rights were violated when the trial court ruled that hearsay evidence—a recording of the victim’s phone call to 9-1-1—was admissible to demonstrate that defendant had contacted the victim in violation of the terms of his probation. Defendant argued that the state did not show good cause for failing to produce the victim at the hearing, and that his confrontation right was thus violated. The trial court revoked probation, and the Court of Appeals affirmed. Defendant argued on appeal to the Oregon Supreme Court that the Court of Appeals erred in adopting a categorical rule that, in a probation revocation hearing, the admission of evidence covered by a “firmly rooted” exception to the hearsay rule always comports with the Due Process Clause of the Fourteenth Amendment. Defendant contended the ordinary balancing test under Oregon v. Johnson (190 P3d 455, rev den, 345 Or 418 (2008)) should have applied, and that, under that test, his confrontation rights were violated. The Oregon Supreme Court concurred with the appellate court's result, but on different reasoning: the state made a strong showing of good cause under the third and fourth Johnson factors that outweighed defendant’s modest interest in confrontation as reflected by the first and second factors. Thus, the admission of the 9-1-1 recording at defendant’s probation revocation hearing did not violate his Fourteenth Amendment confrontation rights.
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