Maus v. State

ADKINS, Judge.

The three cases we now consider present a common question: When a probationer has admitted violations of probation, the probation has been revoked, and a sentence of incarceration imposed, does § 12-302(e) of the Courts and Judicial Proceedings Art. (1984 Repl.Vol.) require that further review be by application for leave to appeal, or does that statute impose that procedure only upon review of a judgment entered after a plea of guilty in a criminal case? The Court of Special Appeals believed that § 12-302(e) applies in the probation context. We do not agree and, therefore,…