State v. Fowler, 175 A.3d 76

Defendant Jamarr Fowler pleaded guilty to interfering with an officer and second‑degree forgery; court imposed a three‑year sentence suspended and three years of probation.
At intake he reported being homeless and living in New York; probation told him an interstate transfer to New York required a valid, verifiable NY address.
Over ~7 weeks probation repeatedly requested a verifiable address; defendant gave addresses that could not be confirmed and refused offers of transitional housing or shelter.
New York denied the transfer because the provided Bronx address was within 1,000 feet of a school given his NY sex‑offender status; Connecticut probation instructed him to return for supervision.
Defendant refused to submit to GPS monitoring when ordered, probation obtained a violation warrant, he was arrested, found to have violated probation for failing to keep probation informed/provide a verifiable address, and the suspended three‑year sentence was imposed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to support probation violation	State: probation presented credible testimony and exhibits showing repeated failures to provide a verifiable address and to keep probation informed	Fowler: he did keep probation informed by phone and in person	Court: There was sufficient evidence by a fair preponderance; finding not clearly erroneous — violation sustained
Authority to impose GPS monitoring	State: not necessary to reach because another proven violation suffices	Fowler: Office of Probation lacked authority to add GPS (not in plea) without a §53a‑30(c) hearing; refusal therefore not a violation	Court: Declined to decide because other proved violation was sufficient to revoke probation
Denial of oral motion to dismiss at VOP hearing	State: —	Fowler: trial court erred in denying his oral motion to dismiss	Court: Issue inadequately briefed on appeal; not reviewed
Revocation and imposition of suspended sentence (abuse of discretion)	State: sentencing within court's broad discretion given noncompliance	Fowler: revocation/sentence was an abuse of discretion	Court: No abuse of discretion; sentence affirmed

State v. Sherrod, 157 Conn. App. 376, 115 A.3d 1167 (probation revocation standard; burden = fair preponderance)
State v. Miller, 83 Conn. App. 789, 851 A.2d 367 (finding VOP on unverified addresses)
State v. Garuti, 60 Conn. App. 794, 761 A.2d 774 (VOP where address investigation disproved defendant’s claim)
State v. Lanagan, 119 Conn. App. 53, 986 A.2d 1113 (single proven condition violation suffices to revoke)
State v. Shakir, 130 Conn. App. 458, 22 A.3d 1285 (trial court’s credibility determinations entitled to deference)
State v. Leary, 51 Conn. App. 497, 725 A.2d 328 (issues inadequately briefed may be declined)
State v. T.R.D., 286 Conn. 191, 942 A.2d 1000 (failure to adequately brief an issue)
State v. Duteau, 68 Conn. App. 248, 791 A.2d 591 (same)
DeFeo v. DeFeo, 119 Conn. App. 30, 986 A.2d 1099 (declining to reach an argument when trial court made no relevant finding)