California, United States of America
The following excerpt is from People v. J.V. (In re J.V.), A151613 (Cal. App. 2018):
1. This right arises as a matter of fundamental fairness under the due process clause of the Fifth Amendment, not the Sixth Amendment confrontation clause. The Sixth Amendment does not apply to probation revocation proceedings. (People v. Johnson (2004) 121 Cal.App.4th 1409, 1411.)
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