132 Conn. App. 335
Conn. App. Ct.2011Background
- Petitioner Gary Sadler involved in a June 26, 1996 shooting resulting in David Moore's death.
- Arrested November 6, 1996; signed a voluntary statement confessing to the killing.
- Petitioner was charged with murder under Conn. Gen. Stat. § 53a-54a.
- Pleaded guilty under the Alford doctrine to manslaughter in the first degree with a firearm; sentenced to 30 years.
- Did not directly appeal his conviction.
- In July 2001, Sadler filed a habeas petition alleging ineffective assistance of trial counsel; court denied and affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court abused its discretion in denying certification to appeal. | Sadler | State | No abuse; issues not debatable or worthy of further review. |
| Whether the first two counts of the petition were properly dismissed as duplicative. | Sadler | State | Counts 1-2 properly dismissed as duplicative of prior petition. |
| Whether the IAC claim against prior habeas counsel has merit. | Sadler | State | No prejudice or deficient performance shown; claim rejected. |
Key Cases Cited
- North Carolina v. Alford, 400 U.S. 25 (1970) (guilty plea despite non-admission of guilt allowed to avoid trial risk)
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes standard for ineffective assistance of counsel)
- Hill v. Lockhart, 474 U.S. 52 (1985) (Guilty plea context; prejudice prong modified for guilty pleas)
- Lozada v. Deeds, 498 U.S. 430 (1991) (requirement to prove ineffectiveness with some objective evidence of unreasonableness)
- Simms v. Warden, 230 Conn. 608 (1994) (state collateral relief standards and, later, abuse of discretion for certiorari petitions)