Supervised Release Revocation & Due Process

Hearsay is not admissible in supervised release revocation hearings unless the government shows good cause to deny the releasee's Due Process right to cross-examine adverse witnesses.
To determine good cause, hearing officers must consider:

1. the reliability of the hearsay, and
2. the cause why the witness is not produced.

United States v. Lloyd (3rd Cir. 2009).

Tender Years Hearsay Exception and Confrontation Clause

A child's statements to her mother as to a sexual assault fell within the tender years hearsay exception and did not violate the right of confrontation. State v. Coder.

New Hearsay Exception

This case introduces a new hearsay exception in New Jersey - Forfeiture-By-Wrongdoing. It applies when a statement is offered against a party who has engaged, directly or indirectly, in wrongdoing that was intended to, and did, procure the unavailability of the declarant as a witness. State v. Byrd