McKinney v. State

A revocation of probation can be ordered because of triggering misbehavior that occurs not only during a period of active probation (the far more common case) but also because of misbehavior occurring before the active probationary period has even begun (the rarer case). Because the overwhelming majority of revocation cases, however, are based on violations occurring while on active probation, there has resulted the inevitable linguistic slippage of the name for that most common instance of the phenomenon being casually misused to denote the larger phenomenon itself, of which it is but a…