People v. Brown (1989)

In People v. Brown (1989) 215 Cal.App.3d 452, the Court of Appeal rejected a contention that appellant's due process rights were violated at a probation revocation hearing because a police officer was permitted to testify regarding the results of a lab test establishing that evidence seized from the defendant was cocaine. (Id. at pp. 454-455.) The Brown court held "as long as hearsay testimony bears a substantial degree of trustworthiness it may legitimately be used at a probation revocation proceeding. In general, the court will find hearsay evidence trustworthy when there are sufficient 'indicia of reliability.' . Such a determination rests within the discretion of the trial court and will not be disturbed on appeal absent an abuse of discretion. ." (Ibid.)