Smith's Criminal Case Compendium
Table of Contents
Evidence
Arrest, Search, and Investigation
Criminal Offenses
Drug Offenses
State v. Willis, 199 N.C. App. 309 (Aug. 18, 2009)
Although a trial court has authority under G.S. 15A-1344(d) to modify conditions of probation, modifications only may be made after notice and a hearing, and if good cause is shown. Although one modification made in this case was permissible as a clerical change, a second modification was substantive and was invalid as it was made without notice and a hearing.