requirement that a revocation hearing in Alabama

2013This Court ‘has recognized, in probation revocation proceedings, only two exceptions to the general rule that issues not presented to the trial court are waived on appeal: (1) the requirement that there be an adequate written order of revocation ..., and (2) the requirement that a revocation hearing actually be held.’ Puckett, 680 So.2d at 983 .” ’ “Bauer v. State, 891 So.2d 1004, 1006 (Ala.Crim.App.2004) (quoting Owens v. State, 728 So.2d 673, 680 (Ala.Crim.App.1998)).

2012This Court ‘has recognized, in probation revocation proceedings, only two exceptions to the general rule that issues not presented to the trial court are waived on appeal: (1) the requirement that there be an adequate written order of revocation ..., and (2) the requirement that a revocation hearing actually be held.’ Puckett, 680 So.2d at 983 .’” “Bauer v. State, 891 So.2d 1004, 1006 (Ala.Crim.App.2004) (quoting Owens v. State, 728 So.2d 673, 680 (Ala.Crim.App.1998)).

2018This Court *134 "has recognized, in probation revocation proceedings, only two exceptions to the general rule that issues not presented to the trial court are waived on appeal: (1) the requirement that there be an adequate written order of revocation ..., and (2) the requirement that a revocation hearing actually be held." Puckett , 680 So.2d at 983 .' " " ' Bauer v. State , 891 So.2d 1004 , 1006 (Ala. Crim.

2018This Court *134 "has recognized, in probation revocation proceedings, only two exceptions to the general rule that issues not presented to the trial court are waived on appeal: (1) the requirement that there be an adequate written order of revocation ..., and (2) the requirement that a revocation hearing actually be held." Puckett , 680 So.2d at 983 .' " " ' Bauer v. State , 891 So.2d 1004 , 1006 (Ala. Crim.

2004See, e.g., Evans v. State, 794 So.2d 1234 (Ala.Crim.App.2000) (noting that the three exceptions to the preservation requirement in probation-revocation proceedings are (1) the requirement that there be an adequate written order of revocation; (2) the requirement that a revocation hearing be held; and (3) the requirement that the trial court advise the probationer of his or her right to request an attorney).

2004See, e.g., Evans v. State, 794 So.2d 1234 (Ala. Crim.App.2000) (noting that the three exceptions to the preservation requirement in probation-revocation proceedings are (1) the requirement that there be an adequate written order of revocation; (2) the requirement that a revocation hearing be held; and (3) the requirement that the trial court advise the probationer of his or her right to request an attorney).

2018This Court *134 "has recognized, in probation revocation proceedings, only two exceptions to the general rule that issues not presented to the trial court are waived on appeal: (1) the requirement that there be an adequate written order of revocation ..., and (2) the requirement that a revocation hearing actually be held." Puckett , 680 So.2d at 983 .' " " ' Bauer v. State , 891 So.2d 1004 , 1006 (Ala. Crim.

2018This Court *134 "has recognized, in probation revocation proceedings, only two exceptions to the general rule that issues not presented to the trial court are waived on appeal: (1) the requirement that there be an adequate written order of revocation ..., and (2) the requirement that a revocation hearing actually be held." Puckett , 680 So.2d at 983 .' " " ' Bauer v. State , 891 So.2d 1004 , 1006 (Ala. Crim.

2010See, e.g., Jackson v. State, 867 So.2d 365 (Ala.Crim.App.2003), and Evans v. State, 794 So.2d 1234 (Ala.Crim.App.2000).” Walker v. State, 920 So.2d 592, 594-95 (Ala.Crim.App.2005).

2009See, e.g., Jackson v. State, 867 So.2d 365 (Ala.Crim.App.2003), and Evans v. State, 794 So.2d 1234 (Ala.Crim.App.2000).” Walker v. State, 920 So.2d 592, 594-95 (Ala.Crim.App.2005).

2009Puckett v. State, 680 So.2d 980, 983 (Ala.Crim.App.1996); Law v. State, 778 So.2d 249, 250 (Ala.Crim.App.2000).” Smith v. State, 26 So.3d 1269, 1271 (Ala.Crim.App.2008).

2007This court has recognized only three exceptions to the general rule that issues not presented to the trial court are waived on appeal: (1) the requirement that there be an adequate written or oral order of revocation, McCoo v. State , 921 So.2d 450 (Ala. 2005); (2) the requirement that a revocation hearing actually be held, Puckett v. State , 680 So.2d 980 (Ala.Crim.App. 1996); and (3) the requirement that the court advise the probationer of his right to request an attorney, Law v. State , 778 So.2d 249 (Ala.Crim.App. 2000).

2010See, e.g., Jackson v. State, 867 So.2d 365 (Ala.Crim.App.2003), and Evans v. State, 794 So.2d 1234 (Ala.Crim.App.2000).” Walker v. State, 920 So.2d 592, 594-95 (Ala.Crim.App.2005).

2009See, e.g., Jackson v. State, 867 So.2d 365 (Ala.Crim.App.2003), and Evans v. State, 794 So.2d 1234 (Ala.Crim.App.2000).” Walker v. State, 920 So.2d 592, 594-95 (Ala.Crim.App.2005).

2008“The general rules of preservation apply to probation revocation hearings.” Owens v. State, 728 So.2d 673, 680 (Ala.Crim.App.1998); see also McCoo v. State, 921 So.2d 446, 448 (Ala.Crim.App.2004), reversed on other grounds, 921 So.2d 450 (Ala.2005)(holding that a hearsay claim was not preserved for review on appeal because it was not raised in the trial court); Puckett v. State, 680 So.2d 980, 983 (Ala.Crim.App.1996) (“[T]his court has recognized, in probation revocation proceedings, only two exceptions to the general rule that issues not presented to the trial court are waived on appeal: (1)

2007This court has recognized only three exceptions to the general rule that issues not presented to the trial court are waived on appeal: (1) the requirement that there be an adequate written or oral order of revocation, McCoo v. State , 921 So.2d 450 (Ala. 2005); (2) the requirement that a revocation hearing actually be held, Puckett v. State , 680 So.2d 980 (Ala.Crim.App. 1996); and (3) the requirement that the court advise the probationer of his right to request an attorney, Law v. State , 778 So.2d 249 (Ala.Crim.App. 2000).

2009Puckett v. State, 680 So.2d 980, 983 (Ala.Crim.App.1996); Law v. State, 778 So.2d 249, 250 (Ala.Crim.App.2000).” Smith v. State, 26 So.3d 1269, 1271 (Ala.Crim.App.2008).

2008Nevertheless, based on Anderson’s admission that he had knowingly failed to report to his probation officer and that he had pleaded guilty to the other charges, the trial judge revoked Anderson’s probation without counsel present. [[Image here]] “ ‘[The Court of Criminal Appeals] has recognized, in probation revocation proceedings, only two exceptions to the general rule that issues not pre *572 sented to the trial court are waived on appeal: (1) the requirement that there be an adequate written order of revocation ..., and (2) the requirement that a revocation hearing actually be held.’ “[Puc

2008Nevertheless, based on Anderson’s admission that he had knowingly failed to report to his probation officer and that he had pleaded guilty to the other charges, the trial judge revoked Anderson’s probation without counsel present. [[Image here]] “ ‘[The Court of Criminal Appeals] has recognized, in probation revocation proceedings, only two exceptions to the general rule that issues not pre *572 sented to the trial court are waived on appeal: (1) the requirement that there be an adequate written order of revocation ..., and (2) the requirement that a revocation hearing actually be held.’ “[Puc

2008“The general rules of preservation apply to probation revocation hearings.” Owens v. State, 728 So.2d 673, 680 (Ala.Crim.App.1998); see also McCoo v. State, 921 So.2d 446, 448 (Ala.Crim.App.2004), reversed on other grounds, 921 So.2d 450 (Ala.2005)(holding that a hearsay claim was not preserved for review on appeal because it was not raised in the trial court); Puckett v. State, 680 So.2d 980, 983 (Ala.Crim.App.1996) (“[T]his court has recognized, in probation revocation proceedings, only two exceptions to the general rule that issues not presented to the trial court are waived on appeal: (1)