Collins v. State, 474 S.W.3d 531

Appellant Jackie Collins pleaded guilty to burglary, received 48 months' probation, later revoked and sent to ADC.
Paroled in 2008; 2014 petition for revocation alleged nonpayment of fines, failure to notify address, and residential burglary/theft.
Trial court found two probation violations (nonpayment and living not in accordance with law) and imposed 120 months in ADC.
On appeal, standard of review: preponderance of the evidence; appellant contests sufficiency of two findings.
Evidence showed fines: $750 fines, $750 original fees, $500 costs; no payments since 2008; appellant claimed confusion about amounts but admitted nonpayment.
Court affirmed revocation, holding first violation proven and theft proven as to a separate condition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the nonpayment of fines inexcusably failing to comply?	Collins argues nonpayment was excusable given confusion/ability to pay.	State argued burden shift to Collins required justification, not mere confusion.	Yes, nonpayment inexcusably proven; affirmed.
Did the evidence support that Collins committed theft under the probation condition?	State contends theft proven by Air Conditioner theft and pawn evidence.	Collins claims lack of authorization; argues services compensation defense.	Yes, theft proven; affirmed.

Egger v. State, 2015 Ark. App. 471 (Ark. App. 2015) ( S.W.3d ; standard deferential review for revocation findings)
Peals v. State, 2015 Ark. App. 1 (Ark. App. 2015) (state need prove one violation; burden on credibility)
Truitt v. State, 2015 Ark. App. 276 (Ark. App. 2015) (burden shift to probationer to justify nonpayment)
Rudd v. State, 61 S.W.3d 885 (2001) (nonpayment alone can constitute violation; credibility vests with trial court)
Burkhart v. State, 2010 Ark. App. 462 (Ark. App. 2010) (confusion about obligation does not excuse nonpayment)
Wade v. State, 983 S.W.2d 147 (1998) (credibility weight lies with trial court)