Byrd v. State

Mark Alan Byrd appeals from the trial court's revocation of his probation. At a previous proceeding, Byrd was convicted of unlawful distribution of a controlled substance and was sentenced to 15 years' imprisonment as a habitual offender. That sentence was suspended for a period of five years, and Byrd was placed on unsupervised probation. Subsequently, Byrd was arrested for disorderly conduct; that arrest resulted in the revocation of his probation.

On appeal, Byrd contends that the trial court erroneously revoked his probation, because, he says, the trial court had failed to issue a written…