Fields v. Commissioner of Correction, 179 Conn. App. 567

Fields was convicted after a jury trial of felony murder, related robbery offenses, and sentenced to 30 years imprisonment plus 20 years special parole. He was 16 at the time of the crime and 17 at trial.
The state had allegedly offered a plea to felony murder with a recommended sentence of 25 years to serve; Fields' trial counsel, Carroll, did not convey the offer to him.
In habeas proceedings Fields argued counsel was constitutionally ineffective for failing to inform him of the 25-year plea offer and that he would have accepted it.
The habeas court found counsel’s performance was deficient (failure to convey the offer) but concluded Fields failed to prove prejudice because the court rejected his testimony that he would have accepted the plea.
The habeas court gave multiple reasons for discrediting Fields’ claim (self‑interest, equivocal testimony, lack of corroborating evidence, his pretrial behavior and juvenile criminal history, counsel’s representation that the case was winnable); the court therefore denied relief and certified the appeal.
The Appellate Court affirmed, holding the habeas court’s credibility determination was entitled to deference and sufficient to defeat the prejudice prong of Strickland.

Issue	Fields' Argument	Commissioner/State's Argument	Held
Whether counsel rendered ineffective assistance by failing to convey a 25-year plea offer	Carroll’s failure to advise of the plea was constitutionally deficient and deprived Fields of choosing the plea	Carroll’s omission was deficient but focus is on whether Fields proved prejudice	Habeas court found performance deficient (conceded) but disposition turned on prejudice; appellate court affirmed denial based on prejudice finding
Whether Fields proved prejudice (reasonable probability he would have accepted the plea)	Fieldstestified he would have accepted the 25-year offer if informed	The only evidence was Fields’ self‑interested, equivocal testimony; habeas court properly rejected it	Appellate court held habeas court’s credibility finding was supported and therefore Fields failed to prove Strickland prejudice

Strickland v. Washington, 466 U.S. 668 (establishing the two‑prong test for ineffective assistance of counsel)
Lafler v. Cooper, 566 U.S. 156 (right to effective assistance extends to plea bargaining)
Ebron v. Commissioner of Correction, 307 Conn. 342 (prejudice in plea‑offer ineffective assistance claims requires reasonable probability the defendant would have accepted and court would have accepted the plea)
Noze v. Commissioner of Correction, 177 Conn. App. 874 (deference to habeas court credibility determinations)
State v. Fields, 265 Conn. 184 (underlying criminal appeal affirming conviction)
McMillion v. Commissioner of Correction, 151 Conn. App. 861 (objective standard for whether a trial judge would have accepted a plea)
United States v. Dominguez Benitez, 542 U.S. 74 (discussion of structural error and harmless‑error principles)
Chapman v. California, 386 U.S. 18 (harmless‑error doctrine and structural errors)