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Name: In re Madison T.
Case #: D062952
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 02/28/2013

The juvenile court did not err when it admitted hearsay testimony of social worker regarding a voicemail left by substance abuse counselor. At a combined juris/dispo hearing regarding the minor, the social worker testified, over appellant mother’s objection, about the contents of a voicemail message left by mother’s substance abuse counselor. On appeal, mother argued that the orders had to be reversed due to the admission of the hearsay testimony. The appellate court disagreed and affirmed. A social worker’s testimony at a dispositional hearing is largely based on hearsay. If it is appropriate for the social worker to rely on evidence in making a dispositional recommendation, it does not matter if the evidence is hearsay, as long as it is reliable, as it was here. Even if it were error to admit the hearsay evidence, it would not have been prejudicial.