State v. Boyd, 151 A.3d 355

Ray Boyd was convicted of murder for a crime committed at age 17 and, in 1992, sentenced to 50 years imprisonment with no parole eligibility.
Boyd unsuccessfully appealed his conviction; his underlying facts were affirmed on appeal.
In 2013 Boyd filed a motion to correct an illegal sentence under Practice Book § 43-22, arguing his sentence was the functional equivalent of life without parole and that the sentencing court failed to consider youth-related mitigating factors required by Miller v. Alabama.
The trial court dismissed the motion for lack of jurisdiction; the state agreed the motion initially raised a viable Miller-based claim.
After enactment of P.A. 15-84 (codified at Conn. Gen. Stat. § 54-125a), Boyd became eligible for parole (for sentences ≤50 years, parole eligibility after 60% served or 12 years), removing the claim that he was serving life without parole.
The Connecticut Supreme Court, following State v. Delgado, held that because Boyd’s sentence now includes parole eligibility, Miller/Riley/Casiano do not require resentencing and the trial court lacks jurisdiction to correct the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentencing is "illegal" because it was the equivalent of life without parole and the court failed to consider youth-related mitigating factors	Boyd: his 50-year, no-parole sentence violated Miller and was illegal because the court did not consider youth-related factors	State: after P.A. 15-84 Boyd is parole-eligible, so the sentence is not life without parole and Miller-based relief is inapplicable	Court: Held Boyd is now parole-eligible; Miller’s remedial rule applies only to life without parole; therefore no colorable illegal-sentence claim and no jurisdiction to correct
Whether a motion to correct was the proper vehicle at the time it was filed	Boyd: motion properly alleged an illegal sentence under Practice Book § 43-22 based on Miller	State: trial court initially erred in dismissing for lack of jurisdiction but contested continuing viability after P.A. 15-84	Court: agreed the motion initially raised a viable claim, but subsequent statutory change eliminated the claim, divesting jurisdiction

State v. Delgado, 323 Conn. 801 (Conn. 2016) (holding changed juvenile-sentencing law can divest jurisdiction for previously viable Miller claims)
Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (mandatory life without parole for juveniles unconstitutional; courts must consider youth-related mitigating factors when imposing life without parole)
State v. Riley, 315 Conn. 637 (Conn. 2015) (Connecticut requires consideration of age-related evidence when imposing life without parole on juvenile offender)
Casiano v. Commissioner of Correction, 317 Conn. 52 (Conn. 2015) (Miller’s sentencing considerations apply retroactively in collateral proceedings)
State v. Boyd, 36 Conn. App. 516 (Conn. App. Ct. 1994) (Appellate Court opinion affirming Boyd’s conviction)