Springs v. State
2017 Ark. App. 364
| Ark. Ct. App. | 2017Background
- Springs pled guilty to second-degree battery on June 6, 2014, and received a 36-month suspended imposition of sentence (SIS) conditioned on good behavior and payment of fines, costs, and fees ($1,000 plus various fees), to be paid $50/month.
- On August 1, 2016, Springs was at the courthouse when an altercation with bailiff Miller Scott occurred; Scott and another bailiff testified Springs injured Scott and resisted detention; Springs denied those facts.
- Springs was arrested that day and later charged with second-degree battery; the State filed a petition to revoke his SIS on August 9, 2016, alleging (1) failure to pay his fines and fees (a $61 unpaid balance) and (2) new criminal conduct violating SIS conditions.
- At the October 12, 2016 revocation hearing the State introduced a payment ledger showing no payments after June 17, 2016; Springs claimed financial necessity (helping the mother of his child) and said he was at the business office to pay.
- The circuit court found Springs had willfully failed to pay and had committed resisting arrest/battery, noted a prior history of violence and an allegedly threatening Facebook post, and revoked the SIS, sentencing Springs to three years’ imprisonment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to revoke Springs' SIS | State: payment ledger + bailiffs’ testimony proved at least one violation (nonpayment and criminal conduct) by preponderance | Springs: denied bailiffs’ account; claimed inability/need to pay others and intended to pay at courthouse | Court: Affirmed revocation; State need only prove one violation by preponderance; court credited State evidence and found Springs’ explanations not credible |
| Whether failure-to-pay was excusable | State: ledger shows nonpayment since June 17, 2016; burden shifted to Springs to show reasonable excuse | Springs: said he was working, paying child’s mother’s fine, and planned to pay at the business office | Court: Found Springs’ excuse insufficient and testimony not credible; willful nonpayment was inexcusable, supporting revocation |
Key Cases Cited
- Mahomes v. State, 427 S.W.3d 123 (Ark. Ct. App.) (evidence insufficient for conviction may suffice for revocation)
- McClain v. State, 489 S.W.3d 179 (Ark. Ct. App.) (appellate review: will not reverse unless findings are clearly against preponderance of evidence)
- Vail v. State, 438 S.W.3d 286 (Ark. Ct. App.) (after State shows nonpayment, burden shifts to probationer to offer reasonable excuse)
- Scroggins v. State, 389 S.W.3d 40 (Ark. Ct. App.) (probationer must justify failure to pay; State retains ultimate burden to show inexcusable nonpayment)
- Peals v. State, 453 S.W.3d 151 (Ark. Ct. App.) (same burden-shifting framework for payment violations)
- Bohannon v. State, 439 S.W.3d 735 (Ark. Ct. App.) (statute requires consideration of factors for inability to pay but does not mandate explicit findings)
- Barbee v. State, 56 S.W.3d 370 (Ark.) (definition of “inexcusable” in payment context)
- Holmes-Childers v. State, 504 S.W.3d 645 (Ark. Ct. App.) (State need prove only one violation to revoke probation/SIS)