In a civil case, in what circumstances was a transcript admissible under California Evidence Code?

2 The transcript itself was admissible under Evidence Code section 1280, which creates an exception to the hearsay rule (Evid.Code, 1200) for official records and writings. (See People v. Abarca (1991) 233 Cal.App.3d 1347, 1350, 285 Cal.Rptr. 213.) However, the testimony in the transcript is hearsay, and the official records exception does not authorize its admission.

3 Article I, section 15 of the California Constitution also guarantees criminal defendants the right to confront witnesses against them. This right is confirmed and iterated in Penal Code section 686. Because defendant confines his claim to the federal constitutional right, we so confine our discussion. Moreover, we doubt an analysis of the claim under our State constitution would be any different. (See, e.g., People v. Louis (1986) 42 Cal.3d 969, 982-983, 232 Cal.Rptr. 110, 728 P.2d 180.)