State v. Morgan, 259 N.C. App. 179

In 2013 Morgan pleaded no contest to two counts of assault with a deadly weapon; the court suspended two consecutive 29–47 month sentences and placed him on 36 months supervised probation.
In May–June 2016 probation officer filed violation reports alleging failures to report, failure to pay court/supervision fees, absconding, and a new misdemeanor conviction for violating a domestic violence protective order; an arrest warrant issued and Morgan was arrested in June 2016.
Morgan’s probation expired on August 28, 2016; a revocation hearing was held September 9, 2016 where Morgan admitted the allegations and counsel attributed recent noncompliance to mental-health issues.
The trial court revoked probation for absconding and the new conviction and activated Morgan’s suspended sentences; the court also announced it would enter a civil judgment for costs and court‑appointed counsel’s fees.
On appeal (certiorari granted despite defective pro se notice), the Court of Appeals affirmed the revocation but vacated and remanded the civil judgment for attorneys’ fees because Morgan was not personally given notice and an opportunity to be heard as to the total fees.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation after probation expired complied with N.C. Gen. Stat. § 15A-1344(f) ("good cause shown and stated")	State: violation reports filed before expiration and hearing/transcript reflect trial court found violations and thus "good cause" to revoke	Morgan: statute requires specific findings of "good cause shown and stated"; none were made	Court: Affirmed revocation — transcript and judgments show the court considered evidence, found violations under revocation-eligible statutes (new offense and willful absconding), satisfying § 15A-1344(f) under controlling precedent (Regan)
Whether entering a civil judgment for appointed counsel’s fees without personally notifying defendant and giving him an opportunity to be heard violated § 7A-455 / precedents (Jacobs, Friend)	State: trial court discussed fees with appointed counsel in open court	Morgan: was not personally asked or given opportunity to address the specific total hours/fees	Court: Vacated and remanded — defendant must be given personal notice and opportunity to be heard about total hours/fees before judgment for attorneys’ fees is entered

State v. Moore, 240 N.C. App. 461 (discussing limits on revocation after probation expiration)
State v. Camp, 299 N.C. 524 (establishing jurisdictional limits on post-expiration revocation)
State v. Regan, 800 S.E.2d 436 (N.C. Ct. App. 2017) (interpreting § 15A-1344(f) as satisfied where court finds violation and the record reflects consideration of evidence)
State v. Bryant, 361 N.C. 100 (Supreme Court: statute requiring the court "finds" requires judicial findings of fact)
State v. Jacobs, 172 N.C. App. 220 (trial court must give defendant notice and chance to be heard re: total hours/fees claimed by appointed counsel)
State v. Friend, 809 S.E.2d 902 (N.C. Ct. App. 2018) (clarifies that trial courts should personally ask defendants if they wish to be heard on fee awards)
In re Appeal from Civil Penalty, 324 N.C. 373 (panels of Court of Appeals are bound by prior published panel precedent)