Background
Dedric Patterson pleaded guilty in October 2024 to second-offense third-degree domestic battery, a Class D felony. He received 120 days in county detention followed by six years’ probation. His probation conditions required him to report for intake, provide a valid address and employment information, make monthly payments toward fines and costs, pay supervision fees, and enroll in a domestic-violence intervention program.
The State sought revocation after Patterson failed to report to probation, provide contact and employment information, pay supervision fees, or make any payment toward $3,400 in fines, costs, and fees. The Crawford County Circuit Court revoked probation and imposed six years in the Arkansas Division of Correction, while satisfying the outstanding court costs and fines. Patterson’s appellate counsel filed a substituted no-merit brief and moved to withdraw.
The Court’s Holding
The Arkansas Court of Appeals held that the revocation was supported by sufficient evidence. Testimony established, without dispute, that Patterson never contacted his probation officer and made no payments toward his financial obligations. Proof of one inexcusable probation violation is enough to support revocation, and the evidence showed multiple violations.
The court also held that the circuit court did not abuse its discretion by rejecting Patterson’s request for county-jail time followed by renewed probation. A six-year prison sentence was within the range authorized for a Class D felony. Community Correction Center placement was unavailable because Patterson’s domestic-battery offense involved causing physical injury and therefore was a violent offense under the applicable eligibility statute. Finding the appeal wholly without merit, the court affirmed and granted counsel’s motion to withdraw.
Key Takeaways
- Uncontroverted evidence that a probationer failed to report and made no required payments supports revocation.
- After revocation, a circuit court may impose any sentence that could have been imposed originally.
- A defendant convicted of an offense involving physical injury was ineligible for Community Correction Center consideration under the cited statutory guidelines.
Why It Matters
The decision illustrates the low evidentiary threshold for probation revocation: the State need prove only one inexcusable violation by a preponderance of the evidence. Here, the record established several.
It also confirms that a lawful prison sentence within the statutory range generally will not be disturbed merely because the defendant sought a lesser alternative, particularly where the defendant failed to comply with the original probation conditions.