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Washington Appellate Court Reverses Parole Revocation Based on Hearsay
Loaded on Nov. 15, 2024
published in Prison Legal News
November, 2024, page 41
On April 2, 2024, the Washington Court of Appeals, Division II, reversed a decision by the state’s Indeterminate Sentence Review Board (ISRB) that relied only on hearsay evidence to sustain a criminal charge underlying a parole violation.
In 2020, ISRB released Lorne Blaylock from prison and transferred him …
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More from this issue:
- Spit Hoods, Modern Legacy of Torture, by Anthony Accurso
- From the Editor
- NYC Rehires Former Head of Rikers Island Lockup Where Guard Assault Left Detainee Quadriplegic
- “Like Being Back in Jail”: Wisconsin Returns Released Sex Offenders to Lifetime GPS Monitoring
- Identities Stolen From Virginia Jail Detainees For $341,205 COVID-19 Fraud
- Alabama Guard, Prisoners Among 13 Sentenced in Phone Scam and Drug-Smuggling Ring
- Facing Bankruptcy, Securus Promotes Prison Tablets
- Fired Missouri Guards Charged with Murder in Prisoner’s Suffocation Death
- California Resentences 15 Condemned Prisoners to Life Without Parole
- Former Virginia Prisoners Win Back Denied Sentence Credits, Sue Over Delayed Release
- California Prisons Ban High-Tech Lie Detector
- Eighth Circuit Asked to Block New FCC Rules Capping Prison Phone Rates and Eliminating Ancillary Fees and Kickbacks
- Florida DOC Failed to Investigate Background of Guard Convicted in Mass Shooting
- $4.77 Million Settlement for Three Alaska Prisoners Exonerated of Murder After 18 Years, by David Reutter
- Alabama Jail Accused of Granting Detainee’s Medical Bond Just Before Death to Avoid Costly Medical Care, by David Reutter
- Kentucky Prisoners Take Advantage of Securus Software Glitch for $1 Million
- $28.75 Million Settlement Paid by New York City in Suit Alleging Rikers Guards Stood by and Watched Detainee Hang Himself, by Douglas Ankney
- Fifth Circuit Revives Texas Prisoner’s Suit Alleging Interference With His Muslim Religious Practice, by David Reutter
- Colorado Becomes First State to Require Polling Stations in Jails
- Two More West Virginia Jailers Plead Guilty in Detainee’s Homicide
- Ninth Circuit: No Qualified Immunity for California Jail Nurse Who Cleared Detainee for Release Just Before His Suicide, by Douglas Ankney
- San Bernardino Jail Partially Released from Court Monitoring After Paying Another $150,000 in Settlements for Detainee Deaths
- Building Carcerality, by Dana McKinney White, Lisa Haber-Thomson
- Corizon Health Bankruptcy Settlement Grows, But Only by $21 Million
- California Throws Prisoners Under the Bus to Adopt New Heat Rules
- PPI Releases 10th Anniversary Report on Mass Incarceration in the U.S.
- Florida Prisoners Exposed to Cancer-Causing Chemicals
- Two Hurricanes in Two Weeks Threaten Prisoners and Jail Detainees in Six States
- Public Defender Files Habeas Petitions for Detainees at “Horrific” Baltimore Lockup
- Another South Carolina Prisoner Convicted of “Sextortion” of U.S. Military Personnel
- $23,138 Plus Out-Of-State Transfer for Virginia Prisoner Who Accused Guards of Excessive Force and Altering Video
- Wellpath Sanctioned for Destroying Evidence in Two Oregon Jail Death Suits, by David Reutter
- Eighth Circuit Upholds Denial of Qualified Immunity to Minnesota Guard Accused of Assaulting Restrained and Compliant Prisoner, by Matthew Clarke
- In Oregon Case, Ninth Circuit Limits Pretrial Detention Without Counsel to Seven Days
- Two Former Georgia Sheriffs Sentenced for Misconduct, Related $5 Million Settlement Approved, by David Reutter
- Washington Appellate Court Reverses Parole Revocation Based on Hearsay
- Illinois Prisoners Stage Hunger Strikes Over DOC Failure to Implement New Sentence Reduction Law
- BOP Ends “Blast” Messages on TRULINCS
- Maryland and Wexford Health Pay $200,000 to Prisoner Denied Care and Partially Blinded, by Douglas Ankney
- Another Payout Brings Arizona Prisoner’s Total to $92,850
- After $750,000 Settlement, Georgia Guard Sued Second Time For Letting One Prisoner Murder Another, by Douglas Ankney
- SCOTUS Stays Texas Execution With 20 Minutes to Spare, by Matthew Clarke
- 50 Years After Starting “Scared Straight,” Former N.J. Prison Warden “Would Do It Again”
- Angola Prisoners Granted Limited Relief From “Farm Line” Work
- Armor Health Liquidates Assets—to Firm’s Founder
- Court Strikes Washington Statute to Regulate GEO Group’s Notorious ICE Lockup
- Milwaukee County Pays $1.05 Million Judgment for Bankrupt Armor Correctional Health to Former Jail Detainee
- California Changes Prisoner Property Policy After Suit Filed Alleging Gender Discrimination Against Men, by Douglas Ankney
- $1.2 Million Settlement Reached in HRDC Censorship Suit Against North Carolina Prison System
- Fifth Circuit Reinstates Former Federal Prisoner’s Suit Over Assault By Guards at Louisiana Lockup, by Matthew Clarke
- $1.5 Million Settlement Approved in Chicago Jail Suicide Case
- $500 Jury Verdict for Pennsylvania Prisoner After Federal Court Clarifies DOC Grievance Procedures
- California Pays $4.45 Million to Prisoners Allegedly Raped by Guards, by Anthony Accurso
- Third Circuit Affirms Qualified Immunity for Pennsylvania Guards Who Pepper-Sprayed Asthmatic Prisoner
- News in Brief
More from these topics:
- Sixth Circuit Announces Predetermining a Supervisee’s Revocation Term of Imprisonment at an Earlier Violation Hearing Renders the Resulting Sentence Both Procedurally and Substantively Unreasonable, June 1, 2026. Revocation Proceedings, Plain Error, Reasonableness of Sentence, Factors To Be Considered.
- Colorado Governor Tells Lawmakers to Open New Prison, April 1, 2026. Corrections Corporation of America/CoreCivic, Cost of Prison Systems, Revocation Proceedings, Reduction of Prison Population.
- Kentucky Supreme Court Clarifies Parole Board May Delegate Final Revocation Hearings to Administrative Law Judges but Holds Due Process Requires Parolees Be Permitted to File Exceptions to ALJ Findings Before Board Renders a Final Revocation Decision, April 1, 2026. Administrative Exhaustion, Fourteenth Amendment, rights, Revocation/Modification of Probation, etc., Revocation Proceedings, Authority and Jurisdiction.
- One in 10 Prison Admissions Is Now for Technical Parole Violation, March 1, 2026. Parole Conditions, State Legislation, Restrictions, discrimination, Revocation Proceedings.
- Fourth Circuit Clarifies Revocation Appeal Provides “Procedurally Appropriate Mechanism” for Raising Rogers Challenge to Unannounced Supervised Release Conditions, Vacates Revocation Judgment Based on Null Standard Conditions, March 1, 2026. Waiver of Appeal Rights, Failure to Object, Revocation Proceedings, Conditions of, Plain Error.
- Delaware Supreme Court Announces Four-Part Plain Error Framework, Aligning Prejudice Standard With Federal Approach Requiring Reasonable Probability of Different Outcome, March 1, 2026. Preservation of Appellate Rights/Issues, Failure to Object, Hearsay Evidence, Confrontation Clause, Plain Error.
- Pennsylvania Supreme Court Announces Presentence Confinement on Probation Detainer Must Be Credited to New Sentence Where Same Conduct Triggered Both Detainer and New Charges, Dec. 15, 2025. Pending Appeal/Sentencing, Statutory Construction/Interpretation, Revocation Proceedings, Credits.
- Maine Supreme Judicial Court Vacates Conviction Based on Confrontation Clause Where Toxicologist Testified About Toxicology Tests Performed by Others, Which SCOTUS Rejected in Smith v. Arizona, Oct. 15, 2025. Forensic Sciences, Testimonial Statements, Crime Lab Reports, Hearsay Evidence, Expert and Opinion Testimony.
- Mississippi Supreme Court Vacates Convictions, Holding Multiple Errors by State Resulted in ‘Legal Chaos’ That Deprived Defendant of Right to Fair Trial Under ‘Cumulative-Error Doctrine’, May 15, 2025. Fifth Amendment, Prejudicial Spillover, Hearsay Evidence, Graphic and Inflammatory Evidence.
- Maryland Supreme Court Clarifies Process for Admitting Co-Conspirator’s Hearsay Statements During Police Interview Under ‘Declaration Against Penal Interest’ Exception, Trial Court Must ‘Parse’ Interview to Determine Admissibility of Each Statement, Feb. 1, 2025. Standard of Review, Police Interrogations, Evidence - Admissibility, Hearsay Evidence, Co-conspirator Statements.

