Vann v. State
In Vann v. State, 16 Ark. App. 199, 698 S.W.2d 814 (1985), the Court said:
A clearly established distinction has been made between arrest for violation of the conditions of a suspended sentence and arrest for other charges in determining whether a revocation hearing under Ark. Stat. Ann. 41-1209(2) (Repl. 1977) [now Ark. Code Ann. 5-4-310(b)(2) (Repl. 1997)] has been held within 60 days of arrest. In Walker v. State, 262 Ark. 215, 555 S.W.2d 228 (1977), the Arkansas Supreme Court held, in regard to the defendant's contention that he was not given a revocation hearing within 60 days of his arrest, that his arrest was for theft of property and not for revocation and, therefore, the 60-day limitation for the revocation hearing as provided in section 41-1209(2), supra, did not apply.
In Reynolds v. State, 282 Ark. 98, 666 S.W.2d 396 (1984), the court again made the same distinction. In that case the court said in regard to the 60-day limitation: "That provision relates to an arrest for violation of the conditions of a suspended sentence and not an arrest on another charge." (16 Ark. App. at 201-02, 698 S.W.2d at 816.)