State of Kansas, Appellee, v. Tiffany Ann Dean, Appellant. (2026)

MEMORANDUM OPINION

Tiffany Ann Dean appeals the district court's decision to extend her term of probation by 12 months. We granted Dean's unopposed motion for summary disposition of her appeal under Supreme Court Rule 7.041A (2026 Kan. S. Ct. R. at 48). After reviewing the record, the arguments in Dean's motion, and the State's response, we affirm the district court's judgment.

Dean pled guilty to possession of methamphetamine. At sentencing in December 2023, the district court imposed a 12-month probation term with an underlying prison sentence of 15 months.

The State moved to revoke Dean's probation in July 2024. The motion noted that Dean resided in Georgia, and that it took until March 2024 for her probation to officially transfer to Georgia. While her probation was being transferred, she took a drug test that was positive for THC and opiates. She was referred to a facility for a drug and alcohol evaluation but never reported to the facility. Dean also stopped reporting to her probation officer in May 2024. The district court issued a bench warrant for Dean on July 26, 2024. Dean was arrested on this warrant on December 24, 2024, in Tennessee.

At the hearing on the alleged probation violations, Dean stipulated to the allegations. Her attorney asked the district court to consider a sanction and extend her probation as punishment for the violations. When given the opportunity to speak, Dean apologized and explained that she did not stop reporting out of defiance, just ignorance of the importance of reporting. She asked the court for another chance on probation, highlighting the fact that she had a job, transportation, and family connections that could help her succeed on probation. The district court extended Dean's probation by 12 months and ordered her to serve a 60-day jail sanction.

On appeal, Dean challenges the district court's decision to extend her probation term by 12 months. She asserts that she stopped reporting only because she moved from Georgia to Tennessee with her fiancé and his three-year-old child. Though she was not reporting, she notes that she demonstrated stability after moving by getting a driver's license and a job. For these reasons, she contends that the district court should have extended her probation for a shorter time.

We review the propriety of the sanction for a probation violation imposed by the district court for an abuse of discretion. State v. Tafolla, 315 Kan. 324, 328, 508 P.3d 351 (2022). A court abuses its discretion if the judicial decision (1) is arbitrary, fanciful, or unreasonable; (2) is based on an error of law; or (3) is based on an error of fact. 315 Kan. at 328. There is no allegation here that the district court made an error of fact or law, so the only question is whether its decision to extend Dean's probation was reasonable.

Here, it was not unreasonable for the district court to extend Dean's probation for 12 months. She stopped reporting a mere two months into the original term of probation and violated other conditions imposed. And the district court's decision gave Dean a second chance to do what she did not do initially, which is to demonstrate that she can comply with the terms of probation for the term of probation originally ordered. We therefore affirm the district court's ruling.

Affirmed.

Cline, J.: