Xavier Estrada v. The State of Texas

Summary

The court affirmed the revocation of Xavier Estrada’s community supervision and ten-year sentence for burglary of a habitation. It held that probation-office chronological records were properly supported under the business-records exception, that the Confrontation Clause did not apply to the revocation proceeding, and that sufficient evidence supported findings that Estrada violated multiple supervision conditions.

Holdings

1. A testifying probation officer need not be the custodian of probation records or have personal knowledge of the underlying events; personal knowledge of how the records were prepared and stored is sufficient to qualify the witness under Texas Rule of Evidence 803(6).
2. The Crawford-type confrontation right does not apply to a community-supervision revocation proceeding because such a proceeding is not a stage of a criminal prosecution.
3. The evidence was sufficient to support revocation because proof of a violation of a single term or condition of community supervision is sufficient, and Mata's testimony established multiple violations by a preponderance of the evidence.

Questions Presented

1. Whether the trial court abused its discretion by admitting probation-office chronological records and testimony about their contents under the business-records exception to the hearsay rule.
2. Whether admitting testimony based on chronological records prepared by other probation officers violated Estrada's federal constitutional right to confrontation.
3. Whether the evidence was sufficient to support revocation of community supervision.

Disposition

affirmed