State v. Ernest Chandler

Syllabus

The defendant, Ernest Chandler, appealed from a Superior Court order denying his motion to vacate an illegal sentence. Chandler had been found to have violated his probation after he was charged with another offense. Chandler argued before the hearing justice that the Superior Court was without authority to declare him a probation violator because, according to Chandler, there were no conditions placed on probation for any defendant before the General Assembly enacted G.L. 1956 § 12-19-8.1 in 2017, eight years after he was sentenced to probation. The Supreme Court held that Chandler's sentence was not illegal given this Court's longstanding rule that keeping the peace and remaining on good behavior are conditions of probation, and that the hearing justice did not act arbitrarily or capriciously when he found that the defendant violated the conditions of his probation to which he was sentenced after his conviction in 2009.