Dylan Nelson v. State of Arkansas

CourtCourt of Appeals of Arkansas
DecidedApril 29, 2026
StatusPublished

This text of Dylan Nelson v. State of Arkansas (Dylan Nelson v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dylan Nelson v. State of Arkansas, (Ark. Ct. App. 2026).

Opinion

Cite as 2026 Ark. App. 255 ARKANSAS COURT OF APPEALS DIVISION II No. CR-25-627

DYLAN NELSON Opinion Delivered April 29, 2026 APPELLANT APPEAL FROM THE BENTON COUNTY CIRCUIT COURT V. [NO. 04CR-18-1913]

STATE OF ARKANSAS HONORABLE ROBIN F. GREEN, APPELLEE JUDGE

AFFIRMED

RAYMOND R. ABRAMSON, Judge

Dylan Nelson appeals the Benton County Circuit Court order revoking his

probation. On appeal, Nelson argues that the circuit court erred by finding that he violated

a condition of his probation. We affirm.

On July 1, 2019, Nelson pled guilty to second-degree domestic battery and second-

degree endangering the welfare of a minor. He was sentenced to sixty months’ probation for

domestic battery and twelve months’ probation for endangering the welfare of a minor.

On June 5, 2024, the State petitioned to revoke Nelson’s probation, and on

November 19, the State filed a second amended petition. In the second amended petition,

the State alleged that on May 20, Nelson committed the new offenses of second-degree

domestic battery, first-degree terroristic threatening, and third-degree domestic battery. The

State further alleged that Nelson possessed a controlled substance and a firearm and had not paid probation-supervision fees totaling $180. The State also claimed that between June 10

and September 17 and between November 4 and November 9, Nelson had violated a no-

contact order.

On December 12, 2024, the court held a revocation hearing. At the beginning of the

hearing, the State introduced a May 23, 2024 no-contact order prohibiting Nelson from

contacting his spouse, Haley Nelson, and their minor children. The State also introduced

emails from a jail account purporting to show contact between Nelson and Haley in June,

July, and September and a jail log showing that Haley had visited Nelson on November 5

and 6.

Officer Benjamin Taylor testified that he is an officer with the Siloam Springs Police

Department and that he responded to a domestic-disturbance call at a residence on May 20,

2024. Officer Taylor explained that at the scene, he spoke with Haley’s mother, Kimberly

Smith, who reported that Nelson had “placed his hands around [Haley’s] throat and in the

process of doing that . . . had hit the infant [son] that she was holding.” He stated that he

then spoke with Haley, and she confirmed Smith’s report. He testified that Haley

additionally informed him that Nelson had “smacked” their eight-year-old daughter across

the face. Officer Taylor testified that he spoke with Nelson’s daughter who confirmed that

Nelson had hit her. Officer Taylor stated that Nelson’s daughter had a welt on her face in

the shape of four fingers. The State introduced photos of Nelson’s daughter’s face.

2 Haley’s mother, Smith, testified that Nelson admitted to her (Smith) that he had

slapped his daughter because “she deserved it.” Smith also stated that the daughter had a red

mark on her face.

Michael Dealy testified that he supervised Nelson’s probation and that Nelson had

failed to pay supervision fees for five months and that he owed $180. On cross-examination,

Dealy stated that Nelson had “reported well” and had not failed a drug test.

At the conclusion of the hearing, the court found that Nelson had violated the terms

of his probation by committing second-degree domestic battery, violating the no-contact

order, and failing to pay his supervision fees. On March 5, 2025, the circuit court entered

findings of fact, and on March 7, the court entered an order revoking Nelson’s probation

and sentencing him to 120 months in the Arkansas Division of Correction. This appeal

followed.

Probation may be revoked upon a finding by a preponderance of the evidence that

the defendant has inexcusably failed to comply with a condition of the probation. Williams

v. State, 2013 Ark. App. 422. On appeal, a revocation will not be overturned unless the

decision is clearly against the preponderance of the evidence. Id. We must give due regard to

the circuit court’s superior position in determining the credibility of witnesses and weight to

be given their testimony. Id. Only one violation is required to sustain a revocation. Springs v.

State, 2017 Ark. App. 364, 525 S.W.3d 490.

On appeal, Nelson argues that the circuit court erred by finding that he violated a

condition of his probation. He challenges all the court’s findings. As to the court’s finding

3 that he failed to pay his supervision fees, Nelson argues that the State failed to prove he

willfully failed to pay. He points out that there was no testimony concerning his employment,

and he asserts that he had reported well and had not failed a drug test.

It is the State’s burden to prove that the failure to pay was inexcusable. Alexander v.

State, 2018 Ark. App. 466, at 3, 561 S.W.3d 744, 746. Once the State has introduced

evidence of nonpayment, the burden of going forward shifts to the defendant to offer some

reasonable excuse for failing to pay. Vail v. State, 2014 Ark. App. 407, 438 S.W.3d 286. It is

then the defendant’s obligation to justify the failure to pay by providing evidence of a

reasonable excuse for the nonpayment. Id. The defendant may not “sit back and rely totally

upon the [circuit] court to make inquiry into his excuse for nonpayment.” Alexander, 2018

Ark. App. 466, at 4, 561 S.W.3d at 746. The State is not required to negate every possible

excuse for nonpayment in its case-in-chief. Reese v. State, 26 Ark. App. 42, 759 S.W.2d 576

(1988). While the ultimate burden of proving inexcusable nonpayment remains on the State,

if the defendant fails to demonstrate a reasonable explanation for his failure to pay, then it

is difficult to find clear error in a circuit court’s finding of inexcusable nonpayment. Springs,

2017 Ark. App. 364, 525 S.W.3d 490.

In this case, Officer Dealy testified that Nelson had not paid his supervision fee for

five months and that he owed $180. After Dealy testified about Nelson’s nonpayment,

Nelson did not provide a justification for his failure to pay. Given these circumstances, we

cannot say that the circuit court’s finding that Nelson violated his probation by inexcusably

failing to pay his supervision fee is clearly against the preponderance of the evidence. Because

4 the State need only prove that Nelson committed one violation, we need not address

Nelson’s arguments concerning the other violations. See Springs, 2017 Ark. App. 364, 525

S.W.3d 490.

Even so, the evidence also supports the circuit court’s finding that Nelson violated

his probation by committing second-degree domestic battery against his daughter. Nelson

argues on appeal that the State failed to prove that his daughter sustained a physical injury

or that he knowingly caused injury to her. He claims the photo of his daughter does not

show markings from physical trauma, and he argues that there was inconsistent testimony

concerning the circumstances surrounding her injury.

A person commits second-degree domestic battery if the person knowingly causes

physical injury to a family or household member he knows to be sixty years of age or older

or twelve years of age or younger. Ark. Code Ann. § 5-26-304(a)(4) (Repl. 2024). Physical

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Reese v. State
759 S.W.2d 576 (Court of Appeals of Arkansas, 1988)
Springs v. State
2017 Ark. App. 364 (Court of Appeals of Arkansas, 2017)
Vail v. State
2014 Ark. App. 407 (Court of Appeals of Arkansas, 2014)
Alexander v. State
561 S.W.3d 744 (Court of Appeals of Arkansas, 2018)
Donnie Raymond Partain v. State of Arkansas
2024 Ark. App. 220 (Court of Appeals of Arkansas, 2024)
Jesse Benton v. State of Arkansas
2020 Ark. App. 223 (Court of Appeals of Arkansas, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Dylan Nelson v. State of Arkansas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dylan-nelson-v-state-of-arkansas-arkctapp-2026.