James Justin Channell v. State of Florida, 200 So. 3d 247

Channell pled nolo contendere to child abuse and was sentenced to 60 days jail plus 3 years probation with a GPS ankle monitor and handheld unit as a condition.
The State filed an 11-count affidavit alleging violations: ten counts for "bracelet gone" alerts (failing to submit to electronic monitoring) and one count for failing to follow probation officer instructions.
At the revocation hearing the probation officer testified from her notes about the GPS "bracelet gone" alerts; no representative from the GPS monitoring company testified or authenticated the company records.
The trial court found Channell violated four "bracelet gone" counts, revoked probation, and sentenced him to 11 months and 15 days jail plus subsequent supervision.
The First District reversed, holding the State failed to lay a proper foundation for admitting the monitoring records under the business-records exception and that the evidence did not prove willful and substantial violations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of GPS/monitoring evidence (hearsay)	State relied on probation officer's notes and testimony about "bracelet gone" alerts to prove violations	Channell argued the evidence was hearsay and the State failed to authenticate records or call monitoring-company personnel to establish business-records exception	Reversed: evidence was inadmissible hearsay because State did not lay predicate for business-records exception (no monitoring-company witness or proper authentication)
Whether violations were willful and substantial	State argued alerts demonstrated noncompliance with monitoring condition	Channell argued alerts were transient, often cleared quickly, and consistent with equipment problems or careless/inadvertent use, not willful disobedience	Reversed: record lacked proof of willful and substantial violation; alerts often cleared and showed no tampering or intentional disregard

Ruise v. State, 43 So. 3d 885 (Fla. 1st DCA 2010) (business-records exception can validate GPS data when foundation is laid by monitoring-company testimony)
Smith-Curles v. State, 24 So. 3d 702 (Fla. 1st DCA 2009) (hearsay is admissible in revocation proceedings but cannot be sole basis for revocation unless an exception applies)
Thomas v. State, 711 So. 2d 96 (Fla. 4th DCA 1998) (hearsay exception principles in probation revocation context)
Edwards v. State, 60 So. 3d 529 (Fla. 2d DCA 2011) (reversing revocation where monitoring reports were hearsay and unsupported by monitoring-company testimony)
Eveland v. State, 189 So. 3d 990 (Fla. 2d DCA 2016) (records inadmissible where State failed to establish predicate via custodian, stipulation, certification, or declaration)
Correa v. State, 43 So. 3d 738 (Fla. 2d DCA 2010) (willful and substantial violation requires more than equipment problems or inadvertent failures)
Cuciak v. State, 410 So. 2d 916 (Fla. 1982) (hearsay principles in probation revocation proceedings)