Bryant Dewight Adams v. State of Arkansas, 612 S.W.3d 191

Bryant Adams pled guilty to aggravated assault on February 4, 2013, and received three years' probation.
The State filed a revocation petition on August 10, 2015; an arrest warrant was issued the same day and returned September 4, 2015.
A second revocation petition was filed January 10, 2017; at a February 13, 2017 hearing the State proceeded on the 2015 petition and the court imposed an additional three years' probation.
The State filed another revocation petition on November 20, 2017; at a June 6, 2019 hearing Adams admitted he failed to report as ordered.
The court found a probation violation, revoked probation, and sentenced Adams to 18 months' imprisonment followed by three years' suspended imposition of sentence; Adams timely appealed.
Adams argued the court lacked jurisdiction to revoke probation in 2017 because the probationary period had already expired; the court held jurisdiction existed because the 2015 warrant was issued before expiration and declined to consider new arguments first raised in Adams’s reply brief.

Issue	Adams's Argument	State's Argument	Held
Whether the circuit court had jurisdiction to revoke probation after the probationary period had expired	Adams: Probation had already expired by the time of the 2017 revocation, so the court lacked jurisdiction	State: A warrant for Adams's arrest was issued in Aug 2015 (before expiration) and returned, preserving the court's jurisdiction to revoke later	Court: Jurisdiction existed because the arrest warrant was issued before the probation expired; revocation was valid
Whether the court should address arguments raised first in Adams's reply brief (e.g., that the 2017 petition superseded the 2015 petition or that no warrant was issued for later petitions)	Adams: The January 2017 petition superseded the 2015 petition; no warrant was issued/served for 2017 petitions	State: Arguments were raised first in reply and thus procedurally defaulted	Court: Declined to address arguments raised initially in the reply brief and noted Adams offered no persuasive authority even if considered

Trif v. State, 503 S.W.3d 802 (Ark. Ct. App. 2016) (explaining jurisdiction to revoke probation may be preserved if a warrant is issued before probation expiration)
Longeway v. State, 553 S.W.3d 180 (Ark. Ct. App. 2018) (argument first raised in a reply brief generally will not be considered)