State v. Williams, 230 N.C. App. 590 (Nov. 19, 2013)

(1) The trial court erred by revoking the defendant’s probation where the State failed to present evidence that the violation report was filed before the termination of the defendant’s probation. As a result, the trial court lacked jurisdiction to revoke. (2) The court declined to consider the defendant’s argument that the trial court had no jurisdiction to revoke his probation in another case because the sentencing court failed to make findings supporting a probation term of more than 30 months. It reasoned that a defendant cannot re-litigate the legality of a condition of probation unless he or she raises the issue no later than the hearing at which his probation is revoked.