The Indiana Court of Appeals held that a revocation petition gave adequate notice of the requested sanction and that consideration of a later, unalleged arrest did not require reversal.
The Wyoming Supreme Court affirmed a probation revocation, holding that the district court erred by determining willfulness during the adjudicatory phase rather than the dispositional phase—a clear violation of Wyoming’s two-part revocation framework—but that the error did not constitute plain error because Smith suffered no material prejudice: he presented his willfulness arguments before the court’s finding and again at disposition, and an independently established, uncontested violation independently supported revocation.