People v. Gray

Summary

The court held that hearsay admitted under the spontaneous-statement exception is not automatically admissible at a probation revocation hearing. The trial court must apply a case-by-case balancing analysis that weighs the probationer's confrontation interests against the government's good cause and other relevant interests, including reliability and corroboration. The court reversed and remanded for the Court of Appeal to conduct that analysis and determine whether any evidentiary error was prejudicial.