State v. Darkis, 502 P.3d 1045

Tremayne M. Darkis pleaded no-contest to marijuana possession; the district court suspended a 30‑month prison sentence and imposed 12 months' probation beginning October 9, 2018.
Probation conditions included reporting to an intensive supervision officer (ISO), attending treatment, obeying laws, and paying fees.
About one week after probation expired, Darkis' ISO sent an "arrest and detain" notice (with an affidavit alleging new arrest, failure to report after federal custody, failure to complete treatment, and unpaid fees) to law enforcement.
Darkis was arrested on that ISO letter; after a revocation hearing the district court found he had absconded and committed a new crime, revoked probation, and ordered him to serve the suspended prison term.
The Court of Appeals held the 30‑day post‑probation window in K.S.A. 2018 Supp. 22‑3716(e) could be triggered by an ISO arrest letter and affirmed, but it reversed on the factual findings (insufficient proof of absconding and new crime) and remanded for intermediate sanctions.
The Kansas Supreme Court granted review on whether subsection (e)'s 30‑day extension requires a warrant or notice to appear; it held (e) applies only to a warrant or notice to appear (not to ISO arrest letters) and reversed the district court (and the Court of Appeals on the authority issue).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether K.S.A. 22‑3716(e)'s 30‑day post‑probation extension authorizes revocation proceedings initiated by an ISO "arrest and detain" notice	State: ISO letter issued within 30 days suffices to authorize court to revoke probation	Darkis: (e) extends only to warrants or notices to appear issued by the court; ISO arrest letters are not covered	Supreme Court: (e) applies only when a warrant or notice to appear is issued; ISO arrest/detain notice does not invoke the 30‑day extension; revocation was without authority
Whether failure to report equals absconding and whether a new crime was proven to permit imprisonment	State: District court findings supported revocation and prison	Darkis: Failure to report is not necessarily absconding; State did not prove a new crime; intermediate sanctions required	Court of Appeals: found insufficient proof and remanded for intermediate sanctions; Kansas Supreme Court did not reach these factual issues because it reversed on the statutory‑authority ground

State v. Samuels, 313 Kan. 876, 492 P.3d 404 (Kan. 2021) (standard of statutory interpretation; review is de novo)
State v. Skolaut, 286 Kan. 219, 182 P.3d 1231 (Kan. 2008) (revocation after probation ends is permissible if a warrant, petition, or show cause order is filed within 30 days)
State v. Gordon, 275 Kan. 393, 66 P.3d 903 (Kan. 2003) (probation revocation allowed where State filed revocation motion within 30‑day window)