Comolli v. State

KELLY, Judge.

Daryl Comolli appeals from the order revoking his probation. He argues that the evidence was insufficient to support the finding that his failure to keep his electronic monitoring device charged was a willful and substantial violation of a term of his probation. We agree and reverse.

At the violation of probation hearing, a records custodian from the electronic monitoring company that monitors probationers’ GPS tracking devices explained that the company is alerted when a probationer’s monitoring unit is not sufficiently charged or when the probationer’s ankle bracelet is' too far…