State v. Kacin is a recent decision from Oregon's Court of Appeals. It holds that, as stated in ORS 137.540(9), failure to pay restitution can never be a sufficient basis to revoke probation. This is true even when the court makes a blanket statement that "the purposes of probation are not being served." In order to lawfully revoke probation under these circumstances, the Court of Appeals suggests that the revoking judge would have to discuss, in greater detail, the purposes of probation and which circumstances inform their opinion that the purposes of probation are not being served.
