State v. Murray
In State v. Murray, 159 Vt. 198, 617 A.2d 135 (1992), the Court concluded that the trial court could not extend a defendant's period of probation beyond that contemplated in a deferred sentence agreement. Murray, 159 Vt. at 199, 617 A.2d at 136.
In that case, defendant agreed to a three year term of probation. Four months after the expiration of her deferred sentence agreement, the court ordered her probation extended until restitution was fully paid.
The Court explained that the court could not extend defendant's probation unless it had notified her of her violation during her probation term. Id. at 200, 617 A.2d at 136.