DEREK MCKINNEY v. STATE OF MARYLAND
Court of Special Appeals of Maryland, Moylan, November 8, 2018,
Revocation of Probation – Probation can be revoked any time after sentencing (even before the active probationary period has begun)

From the Case: When a sentencing judge pronounces an award of probation, probation in its larger sense has begun, regardless of whether probation connotes the immediate status of the defendant (probation in esse) or is simply the promise or expectation of a future probation (probation in potentia) once the active part of the prison sentence has been served. If the judge subsequently learns that the probation is actually not a good risk, it is of no consequence whether that revelation comes while the probation is still in potentia or whether it is already in esse. In either event, it will be revoked.