State v. Sanville

¶ 1. The question before the Court in this case is what style of civil discourse may constitute “threatening behavior.” Defendant appeals from the trial court’s revocation of his probation for violating a condition that read, “Violent or threatening behavior is not allowed at any time.” He contends that he could not have violated the condition because his only action was speaking with no accompanying physical conduct. We reverse because the condition failed to thoroughly apprise defendant of the conduct prohibited.

¶ 2. In 2000, defendant pleaded guilty to a charge of sexual assault on a minor…