State v. Bryan, 229 Conn. App. 364

Ryan Bryan pleaded guilty to assault in the first degree and criminal possession of a firearm, and also to being a persistent dangerous felony offender under Connecticut law.
The plea to the persistent felony offender charge was taken at the same hearing as his plea to the underlying assault offense.
Bryan was sentenced to 17 years, including a 10-year mandatory minimum.
Bryan later filed a self-represented motion to correct an illegal sentence, arguing his guilty plea to the enhancement was procedurally defective because it was not separated from the underlying plea.
The trial court denied his motion on the merits, and Bryan appealed, asserting the court lacked subject matter jurisdiction.
Bryan raised, for the first time on appeal, a claim that the sentencing court failed to specify which part of his sentence was due to the sentence enhancement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had subject matter jurisdiction over Bryan's attack on the plea process via motion to correct	Claim attacked sentence as illegal because of plea procedure, so proper for court to hear	Bryan's challenge targets plea process, so outside motion to correct's scope	Trial court lacked jurisdiction; should have dismissed not denied
Whether to review Bryan's new claim that sentencing enhancement was not specified	Not directly argued	Sentence lacks clarity on enhancement share	Court declined review; should be raised at trial level

State v. Das, 291 Conn. 356 (Connecticut court lacks jurisdiction over motion to correct when challenge is to plea process, not sentence itself)
State v. Smith, 213 Conn. App. 848 (Clarifies scope and review standard for motions to correct illegal sentence)
State v. King, 220 Conn. App. 549 (Reaffirms trial courts lack jurisdiction where motion challenges plea process not sentencing)
State v. Boyd, 204 Conn. App. 446 (Motion to correct attacking plea is a collateral attack, not for sentence review)