State v. Agron, 148 A.3d 1052

In 2006 Angel Agron was released on a $20,000 surety bond executed by 3‑D Bail Bonds, Inc.; Agron failed to appear for a June 23, 2014 date and the trial court forfeited the bond with a six‑month stay.
3‑D investigated and located Agron in Puerto Rico; on December 17, 2014 bail enforcement (fugitive recovery) agents personally confronted him there.
The state’s attorney declined to initiate extradition; Agron attested he was told he was free to go despite the confrontation.
3‑D moved under Conn. Gen. Stat. § 54‑65c to vacate the forfeiture and be released from liability on the bond, submitting affidavits and proof of Agron’s location.
The trial court denied relief, concluding Agron was not “detained or incarcerated” by a governmental authority as § 54‑65c requires; 3‑D filed a writ of error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 54‑65c is satisfied when a fugitive recovery agent personally locates/confronts a principal outside Connecticut	“Detained” includes capture or personal confrontation by bail enforcement agents; that should qualify for vacating forfeiture	“Detained” requires custody by a government entity (another state, territory, country, or federal agency); private bail agents’ actions do not suffice	Court held § 54‑65c requires governmental detention or incarceration; private confrontation did not satisfy statute, so relief denied

Chairperson, Connecticut Medical Examining Board v. Freedom of Information Commission, 310 Conn. 276 (2013) (statutory construction principles and reliance on text/context)
Potvin v. Lincoln Service & Equipment Co., 298 Conn. 620 (2010) (use of dictionary/common meaning when statute lacks definition)
State v. LaFleur, 307 Conn. 115 (2012) (application of noscitur a sociis canon)
State v. Sheriff, 301 Conn. 617 (2011) (surety cannot rely on state to guarantee extradition absent a promise)
Standard Oil of Connecticut, Inc. v. Administrator, Unemployment Compensation Act, 320 Conn. 611 (2016) (presumption of harmonious and consistent statutory scheme)
White v. Mazda Motor of America, Inc., 313 Conn. 610 (2014) (appellate review limits: will not consider issues not raised below)
Graham County Soil & Water Conservation District v. United States ex rel. Wilson, 559 U.S. 280 (2010) (interpretive note on noscitur a sociis)