Bridges v. Commissioner of Correction, 152 A.3d 71

David Bridges entered Alford guilty pleas in two New Haven cases in 2001, represented by trial counsel; he later sought to withdraw the pleas.
The trial court denied his motion to withdraw after an evidentiary hearing and sentenced him to 15 years plus 10 years special parole; the denial was affirmed on direct appeal.
Bridges filed a first habeas petition (ineffective assistance by trial counsel); the first habeas court denied relief and the appeal was dismissed.
In 2014 Bridges filed a second habeas petition alleging his first habeas attorney was ineffective for failing to raise two trial-counsel claims: (1) failure to explain special parole consequences, and (2) failure to investigate/obtain favorable witness testimony.
The second habeas court denied relief and refused certification to appeal; the appellate court reviewed whether that denial was an abuse of discretion and dismissed the appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for failing to ensure Bridges understood consequences of special parole	Bridges: trial counsel never explained special parole, so plea was uninformed and counsel deficient	State: record (including prior habeas findings) and credibility determinations support that counsel adequately advised Bridges	Court: No — habeas court found Bridges’ testimony not credible; no deficient performance or prejudice shown
Whether trial counsel was ineffective for failing to investigate/obtain witnesses (codefendant testimony)	Bridges: counsel did not investigate or secure potentially favorable codefendant testimony, which could have changed plea decision	State: trial counsel testified in first habeas that codefendants could not be compelled to testify; no credible evidence of inadequate investigation	Court: No — petitioner’s testimony was the only support and was rejected; no showing of deficient performance or prejudice
Whether first habeas counsel was ineffective for failing to raise the above trial-counsel claims	Bridges: first habeas counsel should have raised special parole and investigation claims on first habeas	State: first habeas counsel performed professionally; the claims lacked merit and were previously litigated	Court: No — record shows competent representation; no basis to find ineffective assistance

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance: deficient performance and prejudice)
Orcutt v. Commissioner of Correction, 284 Conn. 724 (Conn. 2007) (deference to habeas court on witness credibility and factual findings)
Simms v. Warden, 230 Conn. 608 (Conn. 1994) (standard for appellate review of habeas certification denials)
Jefferson v. Commissioner of Correction, 144 Conn. App. 767 (Conn. App. 2013) (discussion applying Strickland in Connecticut habeas context)
Rodriguez v. Commissioner of Correction, 167 Conn. App. 233 (Conn. App. 2016) (explanation of Alford pleas)
Misenti v. Commissioner of Correction, 165 Conn. App. 548 (Conn. App. 2016) (additional discussion of Alford plea concept)