Kimberly Heaton, Appellant (defendant) v. State of Indiana, Appellee (plaintiff)

Summary

The court held that a probation violation, including the commission of a new criminal offense, must be proven by a preponderance of the evidence under the governing statute, not merely by probable cause. Because the record was unclear about which standard the trial court applied, the court declined to find harmless error, vacated the revocation and sanction order, and remanded for reconsideration. No separate opinions were filed.