In Charles v. State, the Alaska Court of Appeals held that revoking a defendant’s probation for “good cause” does not necessarily depend on the defendant’s willful violation but on whether the corrective aims of probation can be achieved. James Allen Charles Jr. was a repeat sex offender whose probation and parole had been revoked multiple times. Charles struggled to meet his probation obligations, frequently arriving late to his appointments and testing positive for drug and alcohol use. Consequently, the State petitioned to revoke Charles’s probation for missing a polygraph appointment. Despite Charles’s “honest mistake,” the superior court found that Charles had failed to take reasonable steps to avoid missing his appointment. Because his failure to attend had not been due to circumstances outside his control, the superior court determined the violation reflected “a larger pattern of noncompliance with his probation obligations and a failure to fully engage in treatment.” On appeal, Charles argued that it was error to revoke his probation without a finding that he had “willfully” violated its terms. The supreme court disagreed, explaining that the good cause required to revoke probation under section 12.55.110 of the Alaska Statutes does not necessarily require a willful violation. However, the court also rejected the state’s argument that a defendant’s culpability was irrelevant. Instead the court reasoned that it was one of three factors relevant to determining whether good cause exists: (1) the nature of the probation condition violated, (2) the mental state of the violator, and (3) the significance of the violation in terms of whether the defendant is “amenable to continued probation supervision.” The court concluded that good cause exists when continuing the probationary status would “be at odds with the need to protect society and society’s interest in the probationer’s rehabilitation,” and that revocation of probation should only occur when it appears that the “‘corrective aims of probation cannot be achieved.’” Applying this, the court concluded that the superior court’s finding of a pattern of noncompliance was sufficient to support its revocation of Charles’s probation. Affirming, the court of appeals held that revoking a defendant’s probation for “good cause” does not necessarily depend on the defendant’s willful violation but on whether the corrective aims of probation can be achieved
 No. A-12119, 2018 WL 6817302 (Alaska Ct. App. Dec. 28, 2018).