McKINNEY v. STATE

Nos. 130, Sept. Term, 2017 359, Sept. Term, 2017.

196 A.3d 520 (2018)

239 Md.App. 297

Derek McKINNEY v. STATE of Maryland.

Court of Special Appeals of Maryland.

November 8, 2018.


Attorney(s) appearing for the Case

Argued by: Nancy S. Forster , Baltimore, MD, for Appellant.

Argued by: Jessica V. Carter ( Brian E. Frosh , Atty. Gen., on the brief), Baltimore, MD, for Appellee.

Panel: Woodward, C.J., Wright, Charles E. Moylan, Jr. (Senior Judge, Specially Assigned), JJ.


A revocation of probation can be ordered because of triggering misbehavior that occurs not only during a period of active probation (the far more common case) but also because of misbehavior occurring before the active probationary period has even begun (the rarer case). Because the overwhelming majority of revocation cases, however,...

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