DARDEN, J.
In the probable cause affidavit at issue, Detective Zentz first swears and affirms that “he believes and has good cause to believe as a result of his investigation that he learned from reliable persons that the [facts concerning the offenses] occurred [.] . . .” (State’s Ex. 5). The affidavit then describes the statements made by Green to Officer Sharp about the events of September 30, 2010. Detective Zentz states that Green told Officer Sharp that Robinson became angry and pushed her against a wall, squeezed her throat until she couldn’t breathe and fell to the ground, struck her in the back of the head, and pushed her so that she and her son could not leave the apartment. Detective Zentz also states that Green told Officer Sharp that when Robinson hit her in the back of the head, “she landed on her elbows in the bedroom on the carpet.” Id. The affidavit states that Green had “an abrasion on her left elbow that she stated was causing pain from that fall.” Id. Detective Zentz signed the probable cause affidavit following the statement that “I swear or affirm under the penalties for perjury that the above facts are true to the best of my knowledge and belief and that I learned these facts from another law enforcement officer.” Id.
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Robinson contends that the State’s admission of the probable cause affidavit violated his right to confront and cross-examine witnesses. Confrontation rights in the context of probation revocation are not as extensive as they are in criminal trials. Reyes v. State, 868 N.E.2d 438, 440 (Ind. 2007). The Indiana Rules of Evidence, including those governing hearsay, do not apply in such proceedings. See Ind. Evidence Rule 101(c)(2). Additionally, the scope of the right to confrontation as defined in Crawford v. Washington, 541 U.S. 36, 124 S.Ct. 1354 (2004), does not apply in such proceedings. See Reyes, 868 N.E.2d at 440 n.1. However, this “does not mean that hearsay evidence may be admitted willy-nilly in a probation revocation hearing.” Id. at 440. Nonetheless, due process does not prohibit the use “’where appropriate of the conventional substitutes for live testimony, including affidavits, depositions, and documentary evidence.’” Id. (quoting Gagnon, 93 S.Ct. at 1760 n. 5).
In order to admit hearsay evidence at a probation revocation hearing in lieu of live testimony, the State must demonstrate “good cause” for utilizing the hearsay. Id. This requirement is met so long as the hearsay bears substantial guarantees of trustworthiness. Id. at 441. This substantial trustworthiness satisfies the need for flexibility in routine probation revocation hearings. Id. at 441-42. The “substantial trustworthiness test” requires that the trial court evaluate the reliability of the hearsay evidence. Id. at 442. Ideally, the trial court should explain on the record why the hearsay is reliable and why that reliability is substantial enough to supply good cause for not producing live witnesses.” Id. (quoting United States v. Kelly, 46 F.3d 688, 693 (7th Cir. 2006)).
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In the present case, the State emphasizes the trial court’s stated reasons in support of the admission of the multiple hearsay probable cause affidavit. The fact remains that Detective Zentz, the affiant, neither observed the abrasion on Green’s elbow nor any other fact or circumstance of the alleged attack upon Green. Furthermore, the unsworn statement given to Detective Zentz about the abrasion is less than definitive. Officer Sharp merely states that there was an abrasion on Green’s elbow “that she stated was causing pain from the fall.” (State’s Ex. 5).
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We cannot say under the facts and circumstances of this case that the probable cause affidavit was substantially reliable. Accordingly, the trial court erred in admitting the affidavit.
FRIEDLANDER, J., and VAIDIK, J., concur.