In State v. Fuller, 308 Md. 547, 520 A.2d 1315 (1987), the defendant was convicted of several theft offenses in two separate trials. After the defendant was convicted in the first trial, he received a suspended sentence and was placed on three years' probation. The second conviction resulted in another suspended sentence with five years' probation. Thereafter, while on probation, the defendant was charged with uttering a bad check in an attempt to purchase an automobile from a dealership. The new charges, however, were placed on the stet docket. The defendant appeared before the Circuit Court for Harford County for a consolidated hearing for the revocation of his probation in each of his two earlier convictions. Over defense counsel's objection, the trial court admitted and considered hearsay evidence from the stetted case, which consisted of testimony from a police officer who had investigated the matter. The police officer testified as to statements made to him by certain employees of the car dealership. Those employees, however, were not present at the hearing. On appeal, the defendant argued that his due process right to confront and cross-examine adverse witnesses was violated as a result of the absence of the live testimony of the car dealership employees. In its analysis, the Court pointed out that, while a defendant in a probation revocation hearing may not be entitled to all of the protections provided by the U.S. Constitution, the defendant is entitled to "procedural due process" in order to ensure "a fair adjudicative procedure for determining the basis for the revocation of probation." Id. at 552. Analyzing several factors from Gagnon, the Court explained that a defendant in a probation revocation hearing has "'the right to confront and cross-examine adverse witnesses (unless the hearing officer specifically finds good cause for not allowing confrontation).'" Id. The Court established a test to determine whether hearsay evidence was admissible despite an objection based on the Confrontation Clause: Where a party to a probation revocation hearing objects to the admission of hearsay evidence, the threshold question to be resolved is admissibility under the law of evidence of this State. In making that determination the trial judge should keep in mind that in probation revocation proceedings formal rules of evidence are not applied, and that reasonably reliable hearsay may be received. Where there is a confrontation issue the trial judge must undertake additional analyses. The proffered evidence must be tested against the formal rules of evidence to determine whether it fits any of the exceptions to the hearsay rule. If it does, the evidence and exception should then be reviewed to determine whether the criteria for satisfaction of the Confrontation Clause have been met. If the criteria have been met, the evidence may be received on that basis, and no specific finding of good cause need be made. If, however, the proffered hearsay evidence runs afoul of rules of evidence applicable to revocation proceedings or the Confrontation Clause, it cannot be admitted unless it satisfies the standard of reasonable reliability and the trial judge makes, and states in the record, a specific finding of good cause. (Fuller, 308 Md. at 552-53.) Elaborating on the "good cause" requirement, the Court noted that an analysis of U.S. Supreme Court decisions provided "little guidance" but suggested that the trial court may evaluate such factors as: the explanation offered by the State for dispensing with the confrontation, the reliability of the evidence which the State offers in lieu of live testimony, and whether the evidence is offered to prove a probation violation or is merely offered as evidence of such matters as the defendant's general character on probation. (Id. at 553-54, n.5.) The Court determined that the defendant was denied his Sixth Amendment right to confront adverse witnesses when the trial court allowed the admission of the hearsay evidence at his probation revocation hearing. Id. at 554. The Court held that it was error for the trial court to admit the police officer's testimony "because the record contained no finding of good cause for disallowing confrontation, and the excluded evidence did not appear to fall within any exception to the hearsay rule that also satisfies the Confrontation Clause." Id. Concluding its analysis, the Court applied the harmless error standard. The Court determined that the admission of the police officer's testimony in the probation revocation hearing for defendant's first theft conviction was not harmless beyond a reasonable doubt because of the strong likelihood that the hearsay evidence formed the trial judge's basis to revoke defendant's probation. Id. The admission of the same hearsay evidence by the trial judge presiding over the probation revocation hearing for defendant's second theft conviction, however, was determined to be harmless error, as other evidence regarding a separate and unrelated conviction of uttering bad checks was admitted and properly formed the basis to revoke defendant's probation. (Id. at 554-55.)