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Hearsay admissible at revocation sentencing (access required)

The trial court properly admitted appellant’s 2010 probation violation report during the sentencing phase of his 2018 probation revocation hearing. A relaxed standard applies for admitting hearsay during sentencing proceedings. The fact that appellant pleaded guilty to the 2010 violation and the minimal layers of hearsay in the report satisfy the “some-indicia-of-reliability” test, Blunt v. Commonwealth, ...