SMILEY v. STATE, 394 P.3d 1270

Appellant William Hurshel Smiley pleaded guilty to aggravated eluding on June 24, 2013; escape charge was dismissed. He was sentenced to 8 years, with all but 60 days suspended.
The State filed an Application to Revoke Suspended Sentence on October 15, 2014, alleging supervision violations and a new domestic-abuse-by-strangulation charge. Smiley was arraigned, pled not guilty, and waived a 20-day speedy revocation hearing.
An Amended Application to Revoke was filed December 17, 2014, adding allegations of drug use, failure to complete rehabilitation, and additional new crimes (preventing a witness, domestic assault/battery, violation of protective order).
Revocation hearing was held January 20, 2015; the district court found violations and revoked the remaining suspended sentence in full.
On appeal Smiley argued the court violated due process by failing to arraign him on the amended application and thereby denying a fresh 20-day revocation-hearing right.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether filing an amended application to revoke requires a new arraignment and new waiver of the 20-day hearing period	Smiley: the amended application required arraignment and a new waiver, otherwise the 20-day period restarted and lapsed	State: prior arraignment, plea, and waiver covered the revocation proceedings; no new waiver required for amended petition	Court: No new waiver required; prior waiver was effective and 34 days between amendment and hearing was reasonable notice to prepare

Grimes v. State, 251 P.3d 749 (Okla. Crim. App. 2011) (discusses waiver of timely revocation-hearing requirement)
Yates v. State, 761 P.2d 878 (Okla. Crim. App. 1988) (addresses timing and waiver standards for revocation hearings)