Sumpter v. United States

The trial court here made an explicit finding that the government proved by a preponderance of the evidence that Sump-ter had affirmatively concealed the fact of his rearrest and subsequent conviction while on probation.1 I believe the trial court was correct in its view that this act of concealment permitted a revocation of probation on the facts here.

As the majority indicates, our case law has “liberally and broadly” construed the time limit imposed by § 24-104. In Dent v. United States, 465 A.2d 841 (D.C.1983), we held that no formal order of extension was required “to toll the expiration…