In Russeau v. State, 171 S.W.3d 871 (Tex. Crim. App. 2005) the Court ruled that the trial court erred in admitting the defendant's disciplinary records containing inadmissible testimonial statements because the Confrontation Clause's requirements had not been met. Id. at 880. In Russeau, the defendant's disciplinary offenses included "threatening physical harm and even death to others, refusing to work or cooperate, breaking out of his cell at night, exposing himself and masturbating in front of jailers and other inmates, verbally abusing jailers and other inmates, fighting with other inmates, and possessing contraband, including improvised weapons." Id. In concluding that the disciplinary report contained inadmissible testimonial hearsay, the Russeau court found particularly persuasive "the detailed and graphic" nature of the report that recounted appellant's numerous offenses. Id. In Russeau v. State, the reports contained statements that appeared to have been written by corrections officers and purported to document observations, in detailed and graphic terms, regarding numerous disciplinary offenses. Id. at 880. The individuals making those observations did not testify at trial. Id. The court determined that the statements contained in the reports were testimonial in nature and were inadmissible under the Confrontation Clause. Id. The Russeau court specifically held: "The trial court erred in admitting those portions of the reports that contained the testimonial statements." Id. at 881. The Court of Criminal Appeals held the introduction of "incident reports" and prison "disciplinary reports" violated the Sixth Amendment right to confront witnesses. In that case, the court reviewed disciplinary reports that contained detailed statements written by corrections officers where the officers relied on their own observations or observations of others. None of the individuals who observed Russeau's disciplinary offenses testified at his trial. Id. Therefore, the court found the admission of the reports violated his right to confront those witnesses.