State v. Anthony D., 151 Conn.App. 109

Defendant charged with multiple sexual-assault and risk-of-injury counts for abusing his girlfriend’s child; evidence was presented at trial before plea.
After the court denied his motion to suppress his confession, the defendant entered an Alford plea to one count of first‑degree sexual assault in exchange for an agreed sentence (10 years, five years mandatory, plus 10 years special parole); remaining counts nolle prossed.
The trial court conducted a thorough plea canvass at the time of the Alford plea; defendant acknowledged understanding the plea, consequences, and that it was voluntary.
At the sentencing hearing, defense counsel made an oral motion to withdraw the plea, stating only that the defendant had unspecified "concerns" about counsel’s representation and requested new counsel; no specific factual allegations or request for an evidentiary hearing were offered.
The court asked counsel if there were any defects in the plea canvass (counsel said it was thorough), invited the defendant to speak before sentencing (he declined), and denied the oral motion to withdraw without holding an evidentiary hearing.
Defendant appealed, arguing the denial of his motion to withdraw without a more probing inquiry or evidentiary hearing violated due process and his right to counsel; the appellate court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument	Held
Whether the trial court erred by denying an evidentiary hearing on the oral motion to withdraw plea	The court’s canvass and record conclusively refuted any merit to the motion; no specific factual basis was alleged to warrant an evidentiary hearing	The court failed to conduct an adequate inquiry or hold an evidentiary hearing, denying due process and effective assistance of counsel	Court held no error: inquiry was sufficient; motion lacked specific factual allegations and defendant declined to speak when given the chance
Whether the plea was involuntary or resulted from ineffective assistance such that withdrawal was required	Any claim of involuntariness or ineffective assistance could be addressed later (e.g., habeas) and was not supported by the record	Plea was involuntary/tainted by counsel’s ineffective assistance, requiring withdrawal and hearing	Court did not reach merits; concluded defendant bore burden to allege specific facts and did not do so; therefore no evidentiary hearing required

North Carolina v. Alford, 400 U.S. 25 (1970) (authorizes guilty plea while maintaining claim of innocence)
State v. Morant, 13 Conn. App. 378 (1988) (defendant entitled to evidentiary hearing when timely claim of coercion is asserted and court cuts off defendant)
State v. Salas, 885 A.2d 1258 (Conn. App. 2005) (explains when court must hold evidentiary hearing on motion to withdraw plea; defendant must allege specific facts not conclusively refuted by record)