California, United States of America
The following excerpt is from People v. Castro, E067412 (Cal. App. 2018):
First, only where the defendant has stipulated that an officer's statements in a report could be used to demonstrate the factual basis of a conviction may the officer's hearsay statements be used to establish the conduct underlying the conviction. (People v. Saez (2015) 237 Cal.App.4th 1177, 1197.) A later court "'is generally limited to examining the statutory definition, charging document, written plea agreement, transcript of plea colloquy, and any explicit factual finding by the trial judge to which the defendant
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