State v. Moore, 370 N.C. 338

Defendant pleaded guilty/Alford pleas to two sets of breaking-and-entering/larceny-related offenses from Aug–Sep 2012 and received consecutive suspended sentences with supervised probation and standard probation conditions (including "commit no criminal offense").
In June 2015 the State filed two probation-violation reports alleging monetary violations and listing numerous pending criminal charges (by name and case number) under an "Other Violation" heading.
After continuances, a January 2016 hearing included testimony about the newly charged offenses; the trial court found defendant committed fleeing to elude arrest and driving without an operator's license and revoked probation, activating the suspended sentences to run consecutively.
Defendant appealed, arguing the violation reports failed to satisfy N.C.G.S. § 15A-1345(e)’s notice requirement because they did not identify the specific probation condition alleged to be violated.
The Court of Appeals (divided) affirmed; this Court reviewed whether "a statement of the violations alleged" requires naming the probation condition or merely describing the acts alleged to constitute the violation.
The Supreme Court held the statute requires a statement of the defendant's actions that allegedly violated a probation condition (not a requirement to name the specific condition), modified and affirmed the Court of Appeals, and overruled parts of the Court of Appeals line that added a condition-identification requirement post-JRA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 15A-1345(e) requires notice to state the specific probation condition alleged to be violated (versus stating the defendant's conduct)	State: notice need only include a statement of the alleged violations (the acts); listing pending criminal charges satisfied that requirement	Moore: reports were inadequate because they did not identify which revocation-eligible probation condition (post-JRA) was alleged to be violated	Court: Held that § 15A-1345(e) requires a statement of the actions alleged to constitute a violation, not naming the specific condition; listing the pending criminal charges constituted sufficient notice and upheld revocation

State v. Hubbard, 198 N.C. App. 154 (N.C. Ct. App.) (notice satisfied by listing factual allegations of conduct)
State v. Tindall, 227 N.C. App. 183 (N.C. Ct. App.) (Court of Appeals required notice identify revocation-eligible condition; overruled in part)
State v. Kornegay, 228 N.C. App. 320 (N.C. Ct. App.) (applied Tindall’s requirement)
State v. Lee, 232 N.C. App. 256 (N.C. Ct. App.) (applied Tindall/Kornegay; facts where conduct clearly implicated revocation-eligible condition)
Morrissey v. Brewer, 408 U.S. 471 (U.S. 1972) (due-process notice requirements for parole revocation)
Gagnon v. Scarpelli, 411 U.S. 778 (U.S. 1973) (applying Morrissey principles to probation revocation)
Poole v. Miller, 342 N.C. 349 (N.C. 1995) (statutory construction principles)