State must prove violation (Indiana) · Go Syfert
← Indiana issues

State must prove violation in Indiana

23 Indiana opinions name it 2 courts 1979–2026 1 in the last five years

The cases below were cited by Indiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
Devon D. Dokes, Jr. v. State of Indianagreen
indctapp · 2012 · cited in 3 Indiana opinions naming this issue, 2016–2017
2 sentences

2017Dokes v. State, 971 N.E.2d 178, 179 (Ind. Ct. App. 2012). [10] A reviewing court addresses a decision to revoke a placement in a community corrections program the same as a decision to revoke probation.

2016Dokes v. State, 971 N.E.2d 178, 179 (Ind. Ct. App. 2012).

33
Braxton v. Stategreen
ind · 1995 · cited in 3 Indiana opinions naming this issue, 2012–2013
2 sentences

2013“In proving that a defendant has violated the condition of ‘good behavior,’ the State must prove by a preponderance of the evidence that the defendant has engaged in unlawful activity.” Justice v. State, 550 N.E.2d 809, 810 (Ind. Ct. App. 1990). “[I]t is always a condition of probation that a probationer not commit an additional crime.” Braxton v. State, 651 N.E.2d 268, 270 (Ind. 1995), reh’g denied.

2012I.C. § 35-38-2-3(e)1; Braxton v. State, 651 N.E.2d 268, 270 (Ind. 1995), reh’g denied.

33
Abernathy v. Stategreen
indctapp · 2006 · cited in 1 Indiana opinions naming this issue, 2019–2019
1 sentence

2019Abernathy v. State, 852 N.E.2d 1016, 1020 (Ind. Ct. App. 2006). [7] According to Indiana Code section 35-38-2-3(f), to revoke a defendant’s probation due to an alleged violation, “the state must prove the violation by a preponderance of the evidence.” Thereafter, if the State has proved that a violation of probation occurred, the trial court may “[o]rder execution of all or part of the sentence that was suspended at the time of the initial sentencing.” I.C. § 35-38-2-3(h)(3). 1 In this separate criminal proceeding, the trial court granted Murray’s motion to suppress evidence that the State rel

11
Million v. Stategreen
indctapp · 1995 · cited in 1 Indiana opinions naming this issue, 2019–2019
1 sentence

2019Rather, such placement is a “‘matter of grace’” and a “‘conditional liberty that is a favor, not a right.’” Id. (quoting Million v. State, 646 N.E.2d 998, 1002 (Ind. Ct. App.1995)). [9] A revocation hearing is in the nature of a civil proceeding, and the State must prove a violation of the terms of placement by a preponderance of the evidence.

11
Washington v. Stategreen
indctapp · 2001 · cited in 1 Indiana opinions naming this issue, 2019–2019
1 sentence

2019Washington v. State, 758 N.E.2d 1014, 1017 (Ind. Ct. App. 2001).

11
Kimberly Heaton v. State of Indianagreen
ind · 2013 · cited in 1 Indiana opinions naming this issue, 2015–2015
1 sentence

2015See Heaton v. State, 984 N.E.2d 614, 617 (Ind. 2013).

11
Pitman v. Stategreen
indctapp · 2001 · cited in 1 Indiana opinions naming this issue, 2014–2014
1 sentence

2014Pitman v. State, 749 N.E.2d 557, 559 (Ind. Ct. App. 2001).

11
Reyes v. Stategreen
ind · 2007 · cited in 1 Indiana opinions naming this issue, 2014–2014
2 sentences

2014“The State must prove the violation by a preponderance of the evidence.” Id. “[T]here is no right to probation: the trial court has discretion whether to grant it, under what conditions, and whether to revoke it if conditions are violated.” Reyes v. State, 868 N.E.2d 438, 440 (Ind. 2007). “[P]robationers do not receive the same constitutional rights that defendants receive at trial.” Id.

2014“The State must prove the violation by a preponderance of the evidence.” Id. “[T]here is no right to probation: the trial court has discretion whether to grant it, under what conditions, and whether to revoke it if conditions are violated.” Reyes v. State, 868 N.E.2d 438, 440 (Ind. 2007). “[P]robationers do not receive the same constitutional rights that defendants receive at trial.” Id.

11
State v. Monroegreen
ohio · 2006 · cited in 1 Indiana opinions naming this issue, 2013–2013
1 sentence

2013Whatley v. State, 847 N.E.2d 3 1007, 1010 (Ind. Ct. App. 2006).

11
Justice v. Stategreen
indctapp · 1990 · cited in 1 Indiana opinions naming this issue, 2013–2013
1 sentence

2013“In proving that a defendant has violated the condition of ‘good behavior,’ the State must prove by a preponderance of the evidence that the defendant has engaged in unlawful activity.” Justice v. State, 550 N.E.2d 809, 810 (Ind. Ct. App. 1990). “[I]t is always a condition of probation that a probationer not commit an additional crime.” Braxton v. State, 651 N.E.2d 268, 270 (Ind. 1995), reh’g denied.

11
Whatley v. Stategreen
indctapp · 2006 · cited in 1 Indiana opinions naming this issue, 2012–2012
1 sentence

2012Whatley v. State, 847 N.E.2d 1007, 1010 (Ind. Ct. App. 2006).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Indiana. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Runyon v. State green
ind · 2010
2 sentences

2015Runyon, 939 N.E.2d at 616 .

2015Runyon, 939 N.E.2d at 616 .

52012–2015
Curtis L. Bass v. State of Indiana green
indctapp · 2012
2 sentences

2019Rather, such placement is a “‘matter of grace’” and a “‘conditional liberty that is a favor, not a right.’” Id. (quoting Million v. State, 646 N.E.2d 998, 1002 (Ind. Ct. App.1995)). [9] A revocation hearing is in the nature of a civil proceeding, and the State must prove a violation of the terms of placement by a preponderance of the evidence.

2014“The State must prove the violation by a preponderance of the evidence.” Id. “[T]here is no right to probation: the trial court has discretion whether to grant it, under what conditions, and whether to revoke it if conditions are violated.” Reyes v. State, 868 N.E.2d 438, 440 (Ind. 2007). “[P]robationers do not receive the same constitutional rights that defendants receive at trial.” Id.

22014–2019
Hape v. State green
indctapp · 2009
1 sentence

2026Id.

12026–2026
Menifee v. State green
indctapp · 1992
1 sentence

1997IC 35-38-2-3; Menifee, 600 N.E.2d at 970 .

11997–1997
Monroe v. State neutral
indctapp · 1981
1 sentence

1994Monroe v. State (1981), Ind.App., 419 N.E.2d 831 .

11994–1994
Colorado v. Connelly green
scotus · 1986
2 sentences

1989Colorado v. Connelly, 479 U.S. at 168-69 , 107 S.Ct. at 523 , 93 L.Ed.2d at 485 .

1989Colorado v. Connelly, 479 U.S. at 168-69 , 107 S.Ct. at 523 , 93 L.Ed.2d at 485 .

11989–1989
Ortiz v. State green
ind · 1976
2 sentences

1979Burton v. State, (1973) 260 Ind. 94 , 292 N.E.2d 790 ; Ortiz v. State, (1976) 265 Ind. 549 , 356 N.E.2d 1188 .

1979Burton v. State, (1973) 260 Ind. 94 , 292 N.E.2d 790 ; Ortiz v. State, (1976) 265 Ind. 549 , 356 N.E.2d 1188 .

11979–1979
Burton v. State green
ind · 1973
2 sentences

1979Burton v. State, (1973) 260 Ind. 94 , 292 N.E.2d 790 ; Ortiz v. State, (1976) 265 Ind. 549 , 356 N.E.2d 1188 .

1979Burton v. State, (1973) 260 Ind. 94 , 292 N.E.2d 790 ; Ortiz v. State, (1976) 265 Ind. 549 , 356 N.E.2d 1188 .

11979–1979

Statutes the citing opinions construe

IN § Ind. Code § 35-38-2-3 (8) IN § Ind. Code § 35-38-2-1 (3) IN § Ind. Code § 35-38-2.6-5 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 64 (1980–2026) IN 23 (1979–2026) IL 15 (1973–2025) WA 12 (2002–2025) AR 10 (2016–2025) WI 5 (1999–2021) CT 4 (1987–2017) KS 4 (2020–2022) FL 4 (1988–2025) IA 4 (1991–2019) OR 3 (2026–2026) AZ 3 (1982–2020) SD 3 (2002–2013) NE 3 (1989–2014) CA 2 (2006–2011) MS 2 (1992–1996) ND 2 (2013–2014) NC 2 (2003–2012) NJ 2 (1990–2020)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check