☢ test - Í

could result in revocation for more than two years, pursuant to OCGA § 42-8-34.1. See Bergen v. State, 300 Ga.App. 837, 686 S.E.2d 410 (2009). Dillard v. State, 319 Ga.App. 299, 735 S.E.2d 297 (December 12, 2012). Defendant’s probation revocation remanded to clarify record, which suggests that defendant was revoked on grounds not stated in petition. Petition alleged “that Dillard had violated the terms of his probation by committing the offense of possession of a firearm by a convicted felon,” and evidence at hearing supported that contention. “The written revocation orders, however, state only that the trial court found that Dillard violated the conditions of his probation in each case by his unauthorized change of residence and by his failure to report to his probation officer as directed.” “It is well settled that ‘[d]ue process requires that a defendant be given written notice of the claimed violation of his probation prior to [a probation] revocation hearing. In addition, in order to revoke the probationary features of a sentence the defendant must have notice and opportunity to be heard, the notice being sufficient to inform him not only of the time and place of the hearing and the fact that revocation is sought, but the grounds upon which it is based. It may not be revoked where there is no evidence that the defendant violated its terms in the manner charged in the notice, even though there be evidence at the hearing that the defendant violated the terms of probation in some other manner as to which there was no notice given. Likewise, if a judgment is based upon an offense not charged in the petition for revocation, it must be reversed.’ (Citations and punctuation omitted.) Kitchens v. State, 234 Ga.App. 785, 787–788(2), 508 S.E.2d 176 (1998).” Henley v. State, 317 Ga.App. 776, 732 S.E.2d 836 (October 3, 2012). Revocation of defendant’s probation reversed and remanded; revocation was improperly based on hearsay. Defendant allegedly told officer that pills found in his car were oxycodone, “[b]ut this statement was made to an officer who did not testify in court; instead, the statement was repeated by the testifying officer who explained that he was repeating what another officer told him. Henley correctly objected to this statement on hearsay grounds, and the trial court erred by considering it.” Floyd v. State, 317 Ga.App. 619, 732 S.E.2d 527 (September 13, 2012). Probation revocation affirmed; although defendant’s drug possession sentence was unclear, statements on record at sentencing clarified the written sentence, giving defendant fair notice that her sentence could be revoked for failure to attend drug treatment program she was then attending. “Here, the trial court's order was ambiguous in that it did not provide a specific date by which Floyd was required to complete the drug treatment program.[fn] But that is not the end of our analysis. … ‘An accused is entitled to rely on the provisions set forth in the sentencing document if he is not informed to the contrary when the sentence is imposed. ‘ (Citations, punctuation and footnote omitted; emphasis in original.) Otuwa v. State, 303 Ga.App. 410, 411(1) (693 S.E.2d 610) (2010).” Colloquy at sentencing specifically instructed defendant to complete her current treatment program, or her sentence would be revoked. Klicka v. State, 315 Ga.App. 635, 727 S.E.2d 248 (April 13, 2012). Evidence supported defendant’s probation revocation based on failure to report and failure to pay, although probation officer wasn’t sworn. “ Klicka failed to object to any testimony without a proper oath, therefore this argument was waived. See Belcher v. State, 173 Ga.App. 509, 510(1) (326 S.E.2d 857) (1985) (‘appellant's failure to object constituted a waiver of the requirements of an oath’).” Germany v. State, 315 Ga.App. 717, 727 S.E.2d 240 (April 12, 2012). Revocation of probation affirmed; no violation of defendant’s Fifth Amendment rights in “revoking probation for [defendant’s] refusal to take a polygraph examination.” Defendant’s three sentences included the following special condition of probation: “Probationer shall submit to and cooperate with a lie detector test or Psychological Stress Evaluation, whenever so directed by the Probation Supervisor of any city, county or state law enforcement officer concerning any inquiry relative to compliance with the terms of his/her probation. Additionally, probationer shall submit to and cooperate with a lie detector test and/or Psychological Stress Evaluation inquiring into his/her knowledge of criminal activity as may be directed by the Probation Supervisor or by any city, county or state law enforcement officer.” “The evidence here showed that Germany declined to undergo a polygraph examination. As the trial court observed, this is a different situation than agreeing to undergo a polygraph examination and then refusing to answer incriminating questions, which would invoke Fifth Amendment rights. Germany was not forced to answer incriminating questions, and he was never threatened that his invocation of his right not to answer particular questions would result in revocation of his probation. The trial court did not err by concluding that the revocation of Germany's probation for failure to comply with the probation condition requiring him to undergo a polygraph examination did not violate his Fifth Amendment rights.” Based on Minnesota v. Murphy, 465 U.S. 420, 427(II)(A) (104 S.Ct. 1136, 79 L.Ed.2d 409) (1984) (“the general obligation to appear and answer questions truthfully did not in itself convert [the probationer's] otherwise voluntary statements into compelled ones,” as long as the probationer was not “required to answer over his valid claim of the privilege.”); Mann v. State, 154 Ga.App. 677, 681(4) (269 S.E.2d