Alaska v. RansteadAnnotate this Case
The Alaska court of appeals recently read Roman v. Alaska, 570 P.2d 1235(1977) as requiring that a sentencing court affirmatively review all probation conditions proposed in the presentence report, even if the defendant has not objected to those conditions. It applied that requirement to Dean Ranstead’s sentence appeal and remanded to the superior court. The State petitioned for hearing. The Alaska Supreme Court agreed with the court of appeals that a sentencing court bears responsibility for ensuring that probation conditions satisfy the requirements of Roman and are not otherwise illegal. But the Court found a sentencing court was not required to make particularized findings to support the imposition of a proposed probation condition to which the defendant had not objected. Therefore, the Supreme Court reversed the court of appeals’ decision to the extent it vacated probation conditions to which Ranstead did not object.