Anderson v. Sentinel Offender Services, LLC

Because the 1986 amendment to the State-wide Probation Act abrogated common law tolling in significant part with regard to all felony and misdemeanor probationers, I cannot conclude that when the General Assembly removed some misdemeanor probationers in 1991 from the scope of the State-wide Probation Act,8 it intended to revive the common law of tolling for those probationers.

The majority opinion properly finds that common law tolling was applied by the courts of this State to misdemeanor probationers prior to the legislature’s enactment of a tolling statute in 1958 as an amendment to the…