State v. Jalloh, 123012

Bubakarr Jalloh pleaded guilty to aggravated battery (severity level 7 person felony) for a July 28, 2018 offense. The district court imposed an 18‑month sentence, suspended it, and granted 24 months' probation plus 12 months' postrelease supervision.
While on probation, Jalloh pleaded guilty to possession of cocaine (severity level 5 drug felony), creating a new felony conviction.
Jalloh also failed to comply with court‑ordered drug and mental‑health treatment and a domestic violence assessment.
The district court revoked Jalloh’s probation and imposed a modified sentence of 12 months' imprisonment.
Jalloh appealed; the Kansas Court of Appeals granted summary disposition and affirmed the revocation and modified sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by revoking Jalloh's probation after he committed a new felony	Jalloh: the district court erred in revoking probation	State: revocation was authorized by statute when a probationer commits a new felony; Jalloh admitted the new offense and failed treatment orders	Affirmed — no abuse of discretion; revocation and 12‑month modified sentence were permissible

State v. Coleman, 311 Kan. 332, 460 P.3d 828 (2020) (when a felony probationer commits a new felony, revocation is reviewed for abuse of discretion under the statutory exception)
State v. Ingham, 308 Kan. 1466, 430 P.3d 931 (2018) (defines abuse of discretion standard: arbitrary, fanciful, unreasonable, or based on legal/factual error)
State v. Thomas, 307 Kan. 733, 415 P.3d 430 (2018) (appellant bears the burden to show the district court abused its discretion)