State ex rel. Amy Strauser, Relator v. The Honorable Sandy Martinez, (Consolidated with) State ex rel. Sharon Edmonds, Relator v. The Honorable Sandy Martinez, 416 S.W.3d 798

Amy Strauser and Sharon Edmonds each received suspended impositions of sentence and five‑year probation with payment conditions (restitution or court costs).
The State filed motions to revoke when each failed to make required payments; the trial court suspended probation and scheduled revocation hearings before the probation terms expired.
Instead of ruling, the trial court repeatedly continued the revocation hearings and held recurring “case reviews” while the defendants appeared and (in Strauser’s case) made payments.
Strauser’s probation expired June 4, 2012 after numerous continuances; Edmonds’ probation expired September 4, 2008 and the court continued proceedings for years thereafter.
Both defendants sought writs of prohibition to prevent post‑expiration revocation hearings, arguing the court lacked statutory authority because it failed to make “every reasonable effort” to hold the hearings before probation ended under § 559.036.8.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had authority to hold revocation hearings after probation expired under § 559.036.8	Strauser/Edmonds: court lacked authority because it did not make every reasonable effort to notify and conduct hearing before expiration	State: court retained authority because it manifested intent, defendants weren’t ready to proceed, or court could suspend imposition to extend authority	Held: Court lacked authority — although intent and notice existed, the court did not make every reasonable effort to hold the hearings before probation expired, so it could not revoke after expiration
Whether defendant must show they were ready to proceed to satisfy § 559.036.8	Strauser/Edmonds: statute does not require showing of readiness or prejudice	State: defendants failed to show readiness (relying on Petree)	Held: No requirement that defendant show readiness or prejudice; statute conditions extend power only if court meets its obligations
Whether suspending probation or other court actions could circumvent § 559.036.8	State: court can suspend imposition of sentence or otherwise continue to effectively extend probation (relying on Connett)	Strauser/Edmonds: suspension without ruling cannot replace the statutory requirements	Held: Connett is distinguishable; suspension without ruling does not relieve court of obligation to meet § 559.036.8 conditions

State ex rel. Stimel v. White, 373 S.W.3d 481 (Mo. App. 2012) (probation revocation power ends with term absent statutory conditions)
State v. Roark, 877 S.W.2d 678 (Mo. App. 1994) (scheduling a revocation hearing is a manifestation of intent)
Petree v. State, 190 S.W.3d 641 (Mo. App. 2009) (continuance at defendant’s request distinguished from court delay)
State ex rel. Whittenhall v. Conklin, 294 S.W.3d 106 (Mo. App. 2009) (trial court exceeded authority by continuing revocation proceedings years after probation ended)
State ex rel. Breeding v. Seay, 244 S.W.3d 791 (Mo. App. 2008) (court failed to make every reasonable effort where hearings were continued beyond probation term)
State ex rel. Connett v. Dickerson, 833 S.W.2d 471 (Mo. App. 1992) (distinguished: involved imposition of a second probation term rather than an unresolved revocation)
Carlton v. Haynes, 552 S.W.2d 710 (Mo. banc 1977) (discusses prejudice inquiry for unreasonable delay; predated § 559.036)