May, J.
At the [probation revocation] hearing, the State submitted two uncertified documents: an Abstract of Judgment convicting Watters of Class B felony robbery in the Marion Superior Court, and a purported plea agreement resolving that same cause. Watters objected to both arguing they were inadmissible hearsay because they were uncertified. The court overruled Watters’ objections and entered the exhibits into evidence. After the hearing, the court ordered Watters to serve the remainder of his suspended sentence in the Department of Correction.
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Courts may take judicial notice of another county’s conviction in order to revoke probation in the original county of conviction; however, the documents from the other county must be reliable. Christie v. State, 939 N.E.2d 691, 693 (Ind. Ct. App. 2011). We have held the “certification of the documents by the court provides substantial indicia of their reliability.” Pitman v. State, 749 N.E.2d 557, 559 (Ind. Ct. App. 2001), trans. denied. In lieu of certified copies, we have held an affidavit from the issuing agency satisfies the evidentiary requirement for a hearing to revoke probation and proves the document’s underlying “substantial trustworthiness.” Reyes, 868 N.E.2d at 442. Additionally, we have allowed uncertified evidence of a polygraph report, but only to explain the testimony that followed. Peterson, 909 N.E.2d at 499.
In the case at hand, we do not have certified copies, affidavits, or testimony to substantiate the exhibits offered into evidence. Enright testified that she had learned of Watters’ arrest in Marion County, but she did not testify that she had been present at the signing of his plea agreement or at his conviction. The plea agreement is allegedly signed by Watters, but no evidence was entered to substantiate that signature was Watters’ signature. Enright did not testify that she had done anything to corroborate the validity of the documents she received via email.
While trial courts have the discretion to admit hearsay evidence at a probation revocation hearing, the admission must not violate the due process standards provided by the United States Supreme Court. See Gagnon v. Scarpelli, 411 U.S. 778, 781 (1973) (when a loss of liberty is at stake, the parolee is to be accorded due process). We decline to extend the lowered bar for admission of hearsay at probation revocation hearings to include evidence with no “indicia of reliability.” See Cox, 706 N.E.2d at 552 (court is not bound by the hearsay exclusion rule, but the hearsay must be reliable). Although there is no bright line test of this reliability, testimony of the parties directly involved, affidavits of parties directly involved, and certified copies would have sufficed without putting an undue burden on the State. As the State did not provide any of those indicia of reliability herein, we hold the evidence was inadmissible. Cf. Reyes, 868 N.E.2d at 442 (affidavit proved document’s trustworthiness). Accordingly, we reverse.
VAIDIK, C.J. and FRIEDLANDER, J., concur.