Reynolds v. Commissioner of Correction, 140 A.3d 894

Background

Richard Reynolds was convicted by a three‑judge panel and sentenced to death for the 1992 murder of Waterbury police officer Walter Williams, Jr.; this court affirmed on direct appeal in State v. Reynolds.
After direct appeal, Reynolds filed a habeas petition claiming ineffective assistance of trial and appellate counsel and other errors; the habeas court denied relief and certified the appeal.
While the habeas appeal was pending, Connecticut decisions in State v. Santiago and State v. Peeler rendered imposition/carrying out of death sentences unconstitutional under the Connecticut Constitution.
The operative short‑form information charged Reynolds with capital felony by statutory citation and stated date/place; a later long‑form information omitted alleging that the victim was acting within the scope of police duties (an element of capital felony under §53a‑54b(1)).
Reynolds claimed (1) the long form’s omission deprived the trial court of subject matter jurisdiction; (2) trial counsel was ineffective for failing to expose alleged prosecutorial leniency/deal with co‑defendant Anthony Crawford and for not attacking Crawford’s credibility more vigorously; and (3) international law barred his conviction (mostly argued against the sentence).
The court held the death sentence must be vacated under Santiago/Peeler and remanded to convert the sentence to life without release, but affirmed denial of habeas relief on the conviction‑related claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of information / subject‑matter jurisdiction	Long form info failed to allege every element (that officer acted within scope), so trial lacked jurisdiction	Short form plus statutory citation, date/place were filed; that suffices to invoke Superior Court jurisdiction	Rejected: jurisdiction invoked by short form/statutory citation; omission in long form did not strip jurisdiction
Ineffective assistance — prosecutorial misconduct re: Crawford (charging decisions)	Counsel should have alleged misconduct/secret deal because state gave Crawford leniency instead of charging him more seriously	State has broad charging discretion; no evidence of a deal; cooperation/leniency is common and lawful	Rejected: no misconduct shown; counsel not deficient for failing to raise speculative claim
Ineffective assistance — failure to impeach Crawford regarding a deal/acquittal	Counsel should have used Crawford’s acquittal and lack of drug charges to show a deal and impeach credibility	No evidence of a deal; counsel reasonably questioned Crawford about unrelated pending charge rather than speculate; revealing acquittal could have backfired	Rejected: counsel’s strategy reasonable; no deficient performance nor prejudice shown
International law challenge to conviction	International norms prohibit capital punishment and thus bar capital conviction/sentence	Claim mainly targets sentence; no authority provided that international law invalidates capital felony conviction itself	Waived / inadequately briefed as to conviction; court declines to reach international‑law argument on conviction; sentence vacated under Santiago/Peeler

Key Cases Cited

State v. Reynolds, 264 Conn. 1 (affirming Reynolds’ conviction and death sentence)
State v. Santiago, 318 Conn. 1 (Conn. 2015) (holding imposition or carrying out of death penalty violates Conn. Constitution)
State v. Peeler, 321 Conn. 375 (Conn. 2016) (further addressing death penalty invalidation under state constitution)
State v. Commins, 276 Conn. 503 (info need not allege every element to confer jurisdiction)
State v. Crosswell, 223 Conn. 243 (short‑form information with statute and time/place invokes jurisdiction)
Small v. Commissioner of Correction, 286 Conn. 707 (standard for ineffective assistance claims)
Strickland v. Washington, 466 U.S. 668 (Supreme Court standard for ineffective assistance of counsel)