Soden v. State

GARRITY, Judge.

In Cornish v. State, 65 Md. App. 213, 214, 500 A.2d 295 (1985), Judge Wilner observed for this court:

Where the basis of an alleged [probation] violation is a subsequent criminal act — a failure to “obey all laws” or to refrain from the illegal possession or use of drugs or other contraband — it should normally be a simple matter for the State to prove the date of the violation, especially when the probationer has been arrested for and convicted of the subsequent offense. There are police reports, charging documents, witnesses — all manner of evidence sufficient to establish…