CHARLES WILLIAM CALLAHAN v. STATE OF MARYLAND
Court of Special Appeals, Krauser, Filed Nov. 20, 2013,
Probation- Standard “follow lawful instructions of agent” language may not provide basis for violation where it imposes a “new, more onerous condition” that was “not fairly within the ambit of those laid down by the court.”

Where defendant was on parole and on probation, failure to report for parole-required urinalysis could not provide the basis for violation of probation. This where no term of probation included urinalysis.