Smith's Criminal Case Compendium
Table of Contents
Evidence
Arrest, Search, and Investigation
Criminal Offenses
Drug Offenses
State v. High, 230 N.C. App. 330 (Nov. 5, 2013)
The trial court lacked jurisdiction to extend the defendant’s probation after his original probation period expired. Although the probation officer prepared violation reports before the period ended, they were not filed with the clerk before the probation period ended as required by G.S. 15A-1344(f). The court rejected the State’s argument that a file stamp is not required and that other evidence established that the reports were timely filed.