Barnes, J.
The return of service of the ex parte protective order is at issue here. Indiana Trial Rule 4.15(B) provides:
The return, along with the summons to which it is attached or is a part, the praecipe for summons, affidavits furnished with the summons or praecipe for summons, and all other affidavits permitted by these rules shall be filed by the clerk with the pleadings and other papers in the case and thereupon shall become a part of the record, and have such evidentiary effect as is now provided by law. Copies of such record shall be admissible in all actions and proceedings and may be entered in any public records when certified over the signature of the clerk or his deputy and the clerk’s seal.
Ind. R. Trial P. 4.15. Additionally, returns of service are admissible under the public records exception of the hearsay rules. See Ind. Evid. R. 803(8); see e.g., United States v. Union Nacional de Trabajadores, 576 F.2d 388, 391 (1st Cir. 1978) (holding that a sheriff’s return of service was admissible under Federal Evidence Rule 803(8)).
Although our courts have not yet addressed returns of service in the context of the Confrontation Clause, other courts have addressed and rejected the argument made by Gaines. For example, in State v. Copeland, 306 P.3d 610, 627 (Or. 2013), the Oregon Supreme Court addressed the admissibility of a certificate of service of a restraining order in the context of the Confrontation Clause and Crawford. The court noted that “the primary purpose” of the certificate of service “was to serve the administrative functions of the court system, ensuring that defendant, the respondent in the restraining order proceeding, received the notice to which he is statutorily and constitutionally entitled, establishing a time and manner of notice for purposes of determining when the order expires or is subject to renewal, and assuring the petitioner that the subject of the order knew of its existence.” Copeland, 306 P.3d at 627. Because the certificate of service was primarily created for an administrative purpose, the court concluded that “the certificate of service was not testimonial, and its admission did not violate defendant’s Sixth Amendment confrontation rights.” Id. at 628.
Other courts have reached the same result. . . . .
We find these cases instructive. The primary purpose of the return of service is administrative—ensuring that the defendant received notice of the protective order. See I.C. § 34-26-5-9(e) (“The sheriff of each county shall provide expedited service for an order for protection.”). Although the return of service may be used later in a criminal prosecution, the return of service was not created solely for use in a pending or future criminal prosecution. See Melendez–Diaz, 557 U.S. at 323-24, 129 S. Ct. at 2539–2540. As such, we conclude that the return of service was not testimonial, and its admission did not violate Gaines’s rights under the Confrontation Clause.
ROBB, C.J., and BROWN, J., concur.