Rondrae Tramaine Roberts v. State, 05-16-00338-CR

Roberts pleaded guilty to aggravated robbery with a deadly weapon; the trial court deferred adjudication and placed him on ten years’ community supervision.
Approximately 15 months later the State filed a motion to adjudicate, alleging seven violations including failure to report in Nov–Dec 2014 and Jan 2015.
At the contested revocation/adjudication hearing Roberts pleaded not true; the State relied primarily on testimony from a Dallas County probation officer (Vavrick) about probation department records.
Defense objected to Vavrick’s testimony on hearsay, personal-knowledge, and Confrontation Clause grounds; the trial court admitted the testimony after Vavrick testified to the business‑records predicate and overruled confrontation objections.
The trial court found the non‑reporting allegation true, adjudicated Roberts guilty, and sentenced him to ten years’ imprisonment; the court reporter’s record showed Roberts pleaded not true, but the written judgment incorrectly stated he pleaded true.
The court of appeals corrected the judgment to reflect Roberts pleaded not true, rejected his Confrontation and sufficiency challenges, and affirmed as modified.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Roberts)	Held
Whether admitting probation‑record testimony violated the Sixth Amendment Confrontation Clause	Testimony was admissible as business records and revocation is not a “criminal prosecution” for Confrontation Clause purposes	Crawford requires live testimony for testimonial out‑of‑court statements; Vavrick’s testimony about records violated confrontation	Court held Confrontation Clause did not apply to revocation proceedings here; admission was not error
Whether evidence was sufficient to support adjudication for non‑reporting	Probation records and officer testimony showed failure to report Nov–Dec 2014 and Jan 2015; proof of a single violation suffices	Contended the court found a different condition (b) not alleged and evidence was insufficient	Court found the record shows revocation was for nonreporting (allegation d); evidence supported finding; no abuse of discretion

Crawford v. Washington, 541 U.S. 36 (2004) (Confrontation Clause prohibits admission of testimonial hearsay absent prior cross‑examination)
Ex parte Doan, 369 S.W.3d 205 (Tex. Crim. App. 2012) (revocation hearings are judicial proceedings for certain state‑law purposes)
Black v. Romano, 471 U.S. 606 (1985) (due‑process cross‑examination rights in certain postconviction contexts)
Leonard v. State, 385 S.W.3d 570 (Tex. Crim. App. 2012) (revocation implicates liberty interests and due process)
Rickels v. State, 202 S.W.3d 759 (Tex. Crim. App. 2006) (standard of review for revocation is abuse of discretion)
Cobb v. State, 851 S.W.2d 871 (Tex. Crim. App. 1993) (State must prove violations by preponderance; one proven violation suffices for revocation)