Harrell M. McKinney v. State of Arkansas, 612 S.W.3d 172

Harrell McKinney pled guilty (Oct. 16, 2017) to possession of a firearm by certain persons, possession of drug paraphernalia, and drinking in public and received four years' probation.
State filed a petition to revoke probation (July 25, 2018) alleging positive amphetamine test, failure to report, failure to pay supervision fees, and failure to pay fines/costs.
At the revocation hearing (Nov. 1, 2019) probation officer Sabrina Taylor testified McKinney tested positive for amphetamines on April 6, 2018; failed to report as ordered and had not reported since April 6; had not paid supervision fees since March 2018; and provided no proof of paying fines/costs.
The circuit court revoked McKinney's probation and imposed three years' imprisonment plus three years' suspended imposition of sentence.
Appellate counsel filed a no-merit (Anders) brief and moved to withdraw; McKinney was notified of his right to file pro se points but did not do so. The appellate court reviewed the record and affirmed and granted counsel's motion to withdraw.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for revocation	State: Preponderance of evidence showed violations (positive drug test, failure to report, nonpayment).	McKinney: Record insufficient to support revocation.	Affirmed — at least one violation (positive amphetamine test) proved; one violation suffices.
Admission/authentication of Offender/Payee Account document	State: Probation officer familiar with system and authenticated the computer-generated payment log.	McKinney: Document not created by officer; not properly authenticated.	Admission proper (rules not strictly applicable in revocation); even if error, harmless because other violations independently proved.
Probation officer's testimony on treatment benefit	State: Officer's observations about treatment suitability admissible as lay testimony.	McKinney: Testimony speculative, an improper "ultimate opinion," and expert opinion.	Admissible — lay opinion based on officer's dealings; not expert/ultimate-issue error; court did not abuse discretion.

Anders v. California, 386 U.S. 738 (1967) (procedure for counsel to seek withdrawal when appeal is frivolous).
Eads v. State, 47 S.W.3d 918 (Ark. App. 2001) (no-merit brief must list adverse rulings and explain lack of merit).
Tennant v. State, 439 S.W.3d 61 (Ark. App. 2014) (appellate court must independently determine whether appeal is wholly frivolous).
Peals v. State, 453 S.W.3d 151 (Ark. App. 2015) (only one probation condition violation required to revoke).
Humphrey v. State, 458 S.W.3d 265 (Ark. App. 2015) (rules of evidence are not strictly applied in revocation proceedings).