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