State v. Battle, 338 Conn. 523

Defendant Reggie Battle was charged with carrying a pistol without a permit and criminal possession of a pistol, and with violation of probation; he pleaded guilty and received a sentence that involved probation.
After a probation violation and revocation, the trial court imposed a sentence that included a period of special parole.
Battle filed a motion to correct an illegal sentence under Practice Book § 43-22, which the trial court denied; he appealed to the Appellate Court.
The Appellate Court examined whether General Statutes § 53a-32(d) permits imposition of special parole following probation revocation and directed the trial court to render judgment denying Battle’s motion to correct.
The Connecticut Supreme Court granted certification limited to the question whether § 53a-32 authorizes a trial court, after probation violation and revocation, to impose a sentence that includes a period of special parole, and affirmed the Appellate Court’s judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether General Statutes § 53a-32(d) authorizes a trial court, after probation revocation, to impose a sentence that includes a period of special parole	The State: § 53a-32(d) should be read to permit the court to impose a sentence including special parole following revocation	Battle: The statute’s plain language does not mention special parole and therefore does not authorize imposing special parole after revocation	The court affirmed the Appellate Court: § 53a-32(d) does not render the sentence illegal and a trial court may impose a sentence that includes a period of special parole following revocation

State v. Battle, 192 Conn. App. 128 (2019) (Appellate Court opinion addressing whether § 53a-32(d) permits special parole after revocation)
R.T. Vanderbilt Co. v. Hartford Accident & Indemnity Co., 333 Conn. 343 (2019) (cited for adopting an Appellate Court opinion as a proper statement of issues and law)
State v. Henderson, 330 Conn. 793 (2019) (same)