Bullock v. State

1 Citing case

  1. Commonwealth v. Kates

    452 Pa. 102 (Pa. 1973)   Cited 162 times
    Holding that, because there is no statutory or constitutional bar, a court may conduct a VOP hearing prior to trial on the criminal charges which form the basis for the alleged probation violation

    There are other cases dealing with probation violation hearings where the acts constituting the alleged violation amount to criminal activity, but where for some reason there were either no pending criminal charges or the probationer was placed under arrest but the likelihood of his subsequent trial was not noted in the court's opinion. See Bullock v. State, 121 Ga. App. 700, 175 S.E.2d 163 (1970); State v. Washington, 5 Ariz. App. 400, 427 P.2d 381 (1967); Ortega v. State, 414 S.W.2d 465 (Tex.App. 1967). Several federal cases have also rejected the proposition that it is impermissible to conduct revocation of probation proceedings prior to the trial on the criminal charge.