State v. Scott Provost, 133 A.3d 826

Defendant pled guilty in 2012 to second-degree aggravated domestic assault, resisting arrest, and violating conditions of release; he received an agreed sentence of nine months to three years, all suspended, and was placed on probation.
Probation required completion of the DV Solutions domestic-violence program and prohibited violent or threatening behavior; term fixed at one year, expiring June 20, 2013.
A VOP complaint for February 2013 alleged violations of the DV Solutions condition and threatening behavior during a program intake.
Defendant canceled two DV Solutions intake meetings in January 2013 due to a $20 fee; a third intake was scheduled and the PO warned that noncompliance could support a VOP.
The February 13, 2013 intake was contentious: defendant was angry, denied his underlying offenses, and blocked the exit; the counselor felt threatened and summoned a probation officer.
The trial court found violations of both DV Solutions completion and threatening behavior, rejected the pay-argument for the program fee, and extended probation for another year after defendant sought to continue it.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the DV Solutions deadline was properly noticed	State asserts notice via probation officer; completion required by date.	Defendant contends end-of-term completion allowed; no explicit timing.	No plain error; notice adequate; violation proven and extension allowed
Whether the record supports that defendant committed threatening behavior during intake	State maintains threatening behavior occurred during intake.	Defendant disputes that his conduct rose to threatening behavior.	Issue not reached on appeal; upheld by other findings
Whether the trial court properly extended probation and imposed consequences for the violations	State seeks revocation or extension to allow completion.	Requests continuation on probation to complete programs.	Court extended probation by one year and ordered a note of apology; affirmed

State v. Austin, 165 Vt. 389 (1996) (probation violations mixed question of law and fact; defer to findings)
State v. Decoteau, 2007 VT 94 (2007) (plain-error review in probation revocation context)
State v. Gleason, 154 Vt. 205 (1990) (notice requirements and probation-violation standards)
State v. Sanville, 2011 VT 34 (2011) (fair notice of prohibited conduct in probation conditions)
State v. Bostwick, 2014 VT 97 (2014) (limitations on probation officer-imposed timing and interpretation)
State v. Galanes, 2015 VT 80 (2015) (probation condition interpretation; enforce text as written)
State v. Rivers, 2005 VT 65 (2005) (clarity of probation conditions and prohibited conduct)
State v. Ayers, 199? VT 199 (1987) (plain-error standard and constitutional rights)