In the Matter of V.B., 2026 Ind. App. Unpub. LEXIS 190 (Ind. Ct. App. 2026)

The Indiana Court of Appeals reversed a probation violation related to a condition that youth must “obey all laws” based on insufficient evidence. The court stated in relevant part:

“V.B. contends the State did not prove he violated the condition of his probation requiring him to obey the law because he had only been arrested and charged with crimes at the time the probation department filed its petition for modification. When “the alleged [probation] violation is the commission of a new crime, neither an arrest nor the filing of criminal charges alone is enough to warrant probation revocation. Instead, the State must establish by a preponderance of the evidence that the accused has committed the offense.” Mosley v. State, 171 N.E.3d 1031, 1033 (Ind. Ct. App. 2021).”