Arizona Supreme Court

State of Arizona, Appellee v. Christopher Michael Regenold, Appellant

March 1, 2011226 Ariz. 378

Summary

The court held that a defendant who pleads guilty, is placed on probation, and later contests an alleged probation violation may directly appeal the sentence imposed after the contested revocation hearing. The statutory bar on appeals from sentences entered pursuant to plea agreements does not apply because the later sentence results from the probation violation, not directly from the plea agreement. The court reversed the court of appeals and remanded for further proceedings. Justice Pelander, dissenting, would have held that the appeal challenged a sentence controlled by the plea agreement and therefore had to proceed through post-conviction relief.