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Carraway v. Commissioner of Correction
119 A.3d 1153
Conn.
2015
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Background

  • Petitioner Wilton Carraway pleaded nolo contendere to first-degree assault; sentence 15 years with 7 years suspended and 5 years’ probation.
  • Habeas petition filed June 3, 2011 alleging counsel failed to provide information to decide plea versus trial; habeas court denied on prejudice ground.
  • Appellate Court remanded/reversed, finding Copas prejudice standard inconsistent with Hill prejudice standard; held Hill governs prejudicial analysis for guilty-plea cases.
  • Supreme Court of Connecticut concluded respondent was not aggrieved and lacked standing to appeal; dismissed for lack of subject-matter jurisdiction.
  • Court noted Copas has been overruled sub silentio by later decisions and mootness is implicated, but aggrievement resolves jurisdiction.
  • This decision focuses on aggrievement/standing, not on the merits of the Copas-Hill standard itself.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether respondent is aggrieved and has standing to appeal the Appellate Court decision. Carraway argues aggrievement due to personal interest in outcome. Commissioner argues lack of injury to interest; no aggrievement. Appeal dismissed for lack of subject-matter jurisdiction.

Key Cases Cited

  • Copas v. Commissioner of Correction, 234 Conn. 139 (1995) (prejudice standard for ineffective assistance in guilty pleas)
  • Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice standard for guilty pleas under Strickland)
  • Washington v. Commissioner of Correction, 287 Conn. 792 (2008) (Hill standard applied in Connecticut context; later decisions reaffirm)
  • Crawford v. Commissioner of Correction, 285 Conn. 585 (2008) (Strickland prejudice framework in Connecticut context)
  • Johnson v. Commissioner of Correction, 285 Conn. 556 (2008) (Conn. Supreme Court applying Hill framework)
Read the full case

Case Details

Case Name: Carraway v. Commissioner of Correction
Court Name: Supreme Court of Connecticut
Date Published: Jul 21, 2015
Citation: 119 A.3d 1153
Docket Number: SC19347
Court Abbreviation: Conn.