State v. Carter, 142 Conn. App. 156

Carter was convicted in 2002 of multiple offenses and pursued several collateral attacks and writs of habeas corpus.
In 2011 and 2012 Carter filed petitions for a writ of error coram nobis challenging a 2002 pretrial motion and a 2002 post-verdict judgment, respectively.
The trial court denied the first petition as time-barred by a three-year limitation and denied the second petition; both were filed well after the limitations period.
The petitions disclosed they were not timely within three years, raising sua sponte questions about subject matter jurisdiction.
The court held that coram nobis is a remedial, jurisdictional device that requires timely filing and that lack of timely filing implicates jurisdiction.
This Court reversed the judgments as to form and remanded to dismiss for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the three-year limit on coram nobis jurisdiction jurisdictional?	Carter	State	Yes; jurisdictional and untimely filings deprive court of authority.
Should the petitions have been dismissed for lack of jurisdiction rather than merits-based denial?	Carter	State	Judgments should have dismissed for lack of jurisdiction.
Did the court need an objection from the State to proceed on coram nobis petitions?	Carter	State	Court does not require new objection to proceed; lack of timely filing controls.

State v. Das, 291 Conn. 356 (2009) (three-year limitation governs coram nobis)
State v. Henderson, 259 Conn. 1 (2002) (writ of error coram nobis and exceptions to remedies)
State v. Grisgraber, 183 Conn. 383 (1981) (coram nobis not available when adequate remedies exist)
Hurlbut v. Thomas, 55 Conn. 181 (1887) (historic baseline for writ of error coram nobis)
State v. William C., 135 Conn. App. 466 (2012) (three-year limit and jurisdictional effect in appellate review)
State v. Ramos, 306 Conn. 125 (2012) (jurisdictional considerations in coram nobis proceedings)