Reece v. State

Summary

The Supreme Court of Wyoming affirmed the revocation of Dawson A. Reece's probation after he failed to complete an inpatient treatment program. The court held that the probation condition provided adequate notice and that the district court had a sufficient factual basis and did not abuse its discretion in revoking probation.

Holdings

1. The probation terms were sufficiently specific to satisfy due process because the probation order expressly required Reece to successfully complete the WYSTAR Resident Treatment Program, and he understood that failure to complete it would violate probation.
2. The district court did not abuse its discretion in revoking probation because the record adequately established that Reece violated the explicit condition requiring completion of WYSTAR, and the court had a sufficient factual basis for the revocation.

Questions Presented

1. Whether the terms of Reece's probation provided sufficient notice of the required and prohibited conduct to satisfy due process.
2. Whether the district court abused its discretion or acted arbitrarily and capriciously by revoking probation without making more specific findings concerning the violation, willfulness, and reasons for revocation.

Disposition

affirmed