Commonwealth v. Arroyo

The defendant appeals from an order of the Superior Court revoking his probation and committing him to serve a three- to five-year State prison term. The defendant argues that the judge (a) improperly based his decision to revoke probation on an alleged criminal offense that occurred after the probationary term had expired; (b) failed to provide a written statement outlining the reasons for revoking probation; and (c) improperly *229admitted hearsay statements as excited utterances at the revocation hearing.

Procedural history. On December 14, 1999, the defendant pleaded guilty to indictments…