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Dieudonne v. Commissioner of Correction
112 A.3d 157
Conn.
2015
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Background

  • Petitioner Fritzgerald Dieudonne was convicted of assaulting a police officer during an attempted restraint/arrest.
  • Dieudonne filed a petition for a writ of habeas corpus alleging ineffective assistance of trial counsel for not presenting Jessie Boiteux as an eyewitness.
  • Boiteux testified at the habeas proceeding, corroborating Dieudonne’s version and denying the assault or arrest resistance.
  • The habeas court granted the petition, concluding both Strickland v. Washington prongs—deficient performance and prejudice—were satisfied.
  • The Commissioner of Correction appealed, arguing the habeas court misapplied Strickland and weighed the evidence improperly.
  • The Appellate Court affirmed, and the Supreme Court granted certiorari to address Strickland standards; the appeal was ultimately dismissed as improvidently granted.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Did the Appellate Court properly apply Strickland standards? Dieudonne asserts prejudice shown; Boiteux would have been credited. Commissioner contends Strickland standard misapplied and totality weighed differently. Appeal dismissed; certification improvidently granted.

Key Cases Cited

  • Strickland v. Washington, 466 U.S. 668 (1984) (establishes ineffective-assistance standard: performance and prejudice prongs)
  • Dieudonne v. Commissioner of Correction, 141 Conn. App. 151 (2013) (Appellate Court affirmed correct Strickland standard and weighing of evidence)
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Case Details

Case Name: Dieudonne v. Commissioner of Correction
Court Name: Supreme Court of Connecticut
Date Published: Apr 21, 2015
Citation: 112 A.3d 157
Docket Number: SC19140
Court Abbreviation: Conn.