Crouse v. State, 405 P.3d 216

Donald Crouse pleaded no contest to kidnapping and received a suspended 3–6 year sentence with three years’ probation and conditions including a psychiatric evaluation and no contact with the victim’s family.
Probation officer repeatedly instructed Crouse to schedule and complete the psychiatric evaluation; Crouse scheduled a June 27 appointment but left the clinic before completing the intake/evaluation.
The State filed a petition to revoke probation for failure to obtain the psychiatric evaluation; at hearings the State also noted (but did not charge) that Crouse had been observed near the victim’s property.
At the revocation hearing the clinic therapist and probation officer testified about Crouse leaving the evaluation; Crouse did not testify or present witnesses.
The district court found a probation violation by a preponderance of the evidence, concluded the violation was willful, revoked probation, and reinstated the original 3–6 year sentence.

Issue	Appellant's Argument	State's Argument	Held
Whether the district court abused discretion in revoking probation and reinstating sentence	Crouse: violation was not willful because his mental illness impeded compliance; court failed to meaningfully consider that condition	Court reasonably found Crouse knew of the requirement, scheduled but voluntarily left the evaluation, and considered mental illness when imposing sentence	Affirmed — no abuse of discretion; evidence supports willful violation and considered mental health in dispositional analysis
Whether court relied on improper information (unproven allegations/hearsay)	Crouse: court improperly considered uncharged, unsupported allegations (seen near victim) and unverified assumptions about medication compliance	State: prosecutor’s comments were relevant to bond and dispositional considerations; rules of evidence are relaxed in dispositional phase	Affirmed — considering the observations for bond and dispositional purposes was permissible; court did not find medication noncompliance as a violation, only considered incarceration would ensure compliance

Miller v. State, 350 P.3d 742 (Wyo. 2015) (standard of review for probation revocation: discretionary; facts viewed favorably to trial court)
Mapp v. State, 929 P.2d 1222 (Wyo. 1996) (distinguishes adjudicatory and dispositional phases of probation revocation)
Robinson v. State, 378 P.3d 599 (Wyo. 2016) (upholding revocation if court conscientiously determines violation was willful)
Forbes v. State, 220 P.3d 510 (Wyo. 2009) (probation revocation generally requires willful violation)
Edrington v. State, 185 P.3d 1264 (Wyo. 2008) (defines "willfully" in probation context)
Sinning v. State, 172 P.3d 388 (Wyo. 2007) (willfulness is addressed in dispositional phase)
Sharp v. State, 196 P.3d 802 (Wyo. 2008) (mental illness can negate willfulness but does not necessarily do so; evidence may still support willful violation)