Texas Stamp


PD-0251-22 07/27/2022

“The Court of Appeals erred in ruling that the Confrontation Clause does not apply in revocation proceedings because it relied on precedent predating, and/or at odds with, this Court’s jurisprudence as elucidated in Ex Parte Doan.”

At Inman’s deferred-adjudication-revocation hearing, a mental health coordinator, Texas Trooper, and an officer with the Galveston County Community Supervision and Corrections Department testified about multiple violations of the terms of Inman’s supervised release. Inman objected to some of their testimony under the Confrontation Clause. The trial court overruled the objections, revoked Inman’s supervised release, and sentenced her to imprisonment.

On appeal, Inman claimed that her Confrontation Clause rights were violated by the admission of otherwise inadmissible evidence at her hearing. The court of appeals overruled this claim, concluding that the Confrontation Clause does not apply to revocation proceedings. In doing so, the court relied on numerous intermediate appellate court decisions.

Inman contends that Ex parte Doan, 369 S.W.3d 205 (Tex. Crim. App. 2012), undermines the appellate court decisions cited by the court of appeals. Several of those cases pre-date Ex parte Doan, and the other post-Ex parte Doan cases failed to give it due consideration. Inman points out that, while Ex parte Doan did not explicitly address this issue, it characterized revocations as non-administrative, judicial proceedings governed by traditional judicial-proceeding rules. She also notes that a few intermediate appellate courts since Ex parte Doan have held or assumed that the Confrontation Clause does apply. Inman, therefore, urges the Court of Criminal Appeals to settle the issue.

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