State v. High, 230 N.C. App. 330

Defendant pled guilty to six counts of breaking or entering a motor vehicle on 21 July 2008 and received two consecutive six-to-eight month terms; sentences suspended for split sentence of 30 days in jail followed by 24 months of supervised probation, expiring 20 July 2010.
Probation officer filed two violation reports on 1 March 2010 alleging curfew violations, cocaine use, marijuana possession, underage drinking, and arrears; reports signed by officer and Deputy Clerk but lacked a filing time stamp.
On 20 September 2010 the trial court extended probation by 24 months based on the 1 March 2010 reports.
On 22 June 2011 two new violation reports alleged failure to report, arrears, and absconding supervision.
On 3 August 2011 the court modified probation, ordering monetary payments and 30 days jail (potentially served on weekends).
On 9 March 2012 two violation reports alleged arrears, absconding, and four charges pending; at a 6 August 2012 hearing defendant admitted to absconding, probation revoked, and sentences activated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had subject matter jurisdiction to revoke probation after expiration.	State: violation reports timely filed under §15A-1344(f) despite no time stamp.	High lack of timely filing voids jurisdiction.	Jurisdiction lacking; arrest judgment and vacate.
Whether waiver of counsel was knowing and voluntary or compliant with Rule 15A-1242.	Not stated in the excerpt; argued on appeal.	Waiver valid per procedural rules.	Not reached/undetermined.

State v. Satanek, 190 N.C. App. 653 (2008) (probation revocation requires timely filing; lacks jurisdiction otherwise)
State v. Hicks, 148 N.C. App. 203 (2001) (extension of probation after expiration requires proper procedure)
State v. Moore, 148 N.C. App. 568 (2002) (lack of file-stamped filing deprives trial court of jurisdiction)