In Brian Woods v. State of Indiana, No.49S04-0808-CR-469, the court examined the concept and implications of a "strict compliance" probation, which Woods was on after previously failing to make mandatory drug screenings. The trial court warned him that if he violated his probation again, his 15-year prison sentence would be reinstated. The prosecutor agreed to reduce the sentence to 12 years.
Woods appealed the revocation of his probation, arguing the court denied him due process by preventing him from explaining why he violated his probation.
Because the trial court denied Woods the opportunity to explain why he missed the screenings at his second revocation hearing, he was denied due process, wrote Justice Robert Rucker. However, the Supreme Court found Woods is not entitled to relief.
Woods never made any attempt on direct appeal or on transfer to the Supreme Court to explain why he violated his probation, nor did he make an offer of proof to the trial court, wrote the justice.
"Generally this failure is fatal to his claim," he wrote.