The People of the State of Colorado v. Michael Garcia

Summary

The court held that a notarized return of service for a temporary protection order was not testimonial hearsay because its primary purpose when created was administrative record-keeping and providing notice, not establishing facts for a future prosecution. Its admission without testimony from the process server therefore did not violate the defendant's confrontation right. The court reversed the district court's judgment and remanded for reinstatement of the conviction and sentence.