Does a defendant have a right of confrontation at a probation revocation hearing?

As noted, a defendant has only a limited right of confrontation at a probation revocation hearing, and it arises from the due process clause rather than the Sixth Amendment. (People v. Johnson, supra, 121 Cal.App.4th at p. 1411.) Therefore, defendant's argument regarding a violation of the confrontation clause is to no avail. Moreover, as held in Abrams, the fact of whether or not a defendant has reported to the probation officer (or as in this case, the assigned program) is "essentially nontestimonial; thus, even if hearsay," it is admissible at the probation violation hearing. (Abrams, supra, 158 Cal.App.4th at p. 398.) Since we have found that the hearsay evidence was properly admitted by the court, defendant has suffered no due process violation. Furthermore, there was sufficient evidence to support the trial court's finding by a preponderance of the evidence that defendant willfully violated the terms and conditions of probation. (Abrams, supra, 158 Cal.App.4th at p. 400.) Not only did the court have a probation

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