Drew Thomas Majors v. State of Indiana (mem. dec.), 48A02-1705-CR-1171

Majors pled guilty to Level 6 felony residential entry and Class A misdemeanor theft; sentenced to 2 years with 1 year executed and 1 year suspended to probation (sentences concurrent).
Probation officer filed a violation notice alleging failures to report, obtain a GED, get substance-evaluation/treatment, positive drug test for cannabinoids, and failure to maintain employment.
Probation later amended the notice to add two new criminal charges: Level 3 aggravated battery and Level 6 auto theft.
At the revocation hearing Majors admitted to the first five violations; the State presented evidence of the new criminal charges.
The trial court found the State proved the new crimes, revoked probation, and ordered Majors to serve the previously suspended one-year sentence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Majors)	Held
Whether the trial court abused its discretion by revoking probation	Probation revocation proper based on admitted violations and proof of new crimes	Revocation improper because employment failure was involuntary and evidence of new crimes was hearsay	No abuse; single valid violation suffices and Majors admitted multiple violations
Whether ordering execution of the suspended one-year sentence was an abuse of discretion	Execution warranted given repeated and substantial probation violations shortly after release	Imposition improper because court relied on alleged new crimes that were improperly admitted	No abuse; trial court has broad discretion and admitted violations alone supported execution

Luke v. State, 51 N.E.3d 401 (Ind. Ct. App. 2016) (a single probation condition violation can justify revocation)
Cox v. State, 706 N.E.2d 547 (Ind. 1999) (probation is discretionary grace, not a right)
Gilfillen v. State, 582 N.E.2d 821 (Ind. 1991) (probation described as conditional liberty and a favor)
Prewitt v. State, 878 N.E.2d 184 (Ind. 2007) (trial courts have considerable leeway in post-revocation sentencing)