Eighth Circuit: United States v. Stevenson Harrison

Hearsay in parole revocation hearing.

Where the District Court does not explicitly permit hearsay evidence at a parole revocation hearing, the appellate court can conduct a de novo review on the question if the factual record is sufficiently developed.

Where the costs of producing evidence at a parole revocation hearing are unduly burdensome and impractical, no abuse of discretion in admitting parole officer testimony and police reports.

Virginia statute of Malicious Bodily Injury to Law Enforcement Officer is categorically a Grade A/ violent offense.

Dissent - FRCrimP requires specific admission of hearsay as hearsay.  Parole officer testimony derived from reading the police reports.  Deft's corroborating statements limited to attempting to run away, and being grabbed by police officers, who subsequently ripped his shirt and fell down a flight of stairs.  Subsequent alleged fracas unconfirmed.

http://media.ca8.uscourts.gov/opndir/15/12/151246P.pdf