State v. Cruz, AC36420

Cruz pleaded guilty to first-degree manslaughter and evasion of responsibility, yielding a total sentence of 19 years, pursuant to a plea agreement.
After sentencing, Cruz filed two Practice Book § 43-22 motions to correct an illegal sentence.
First motion alleged Brady violations—withheld exculpatory evidence—and claimed it affected sentencing mitigation.
Second motion alleged the sentencing court impermissibly participated in pretrial plea negotiations.
The trial court, after hearings, dismissed both motions as not raising a valid basis to correct an illegal sentence.
Cruz appealed, arguing the court lacked jurisdiction to adjudicate the motions for two Brady/plea negotiation grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brady claims in a § 43-22 motion invoke jurisdiction	Cruz argues Brady evidence affects sentence mitigation.	State argues Brady claim attacks conviction, not sentence.	No jurisdiction; Brady claim not within § 43-22 scope.
Whether the sentencing court's pretrial plea participation renders sentence illegal	Cruz contends court improperly participated in plea negotiations, violating rights.	State argues § 39-7, 39-16 do not limit pretrial court role; Revelo allows such participation under certain conditions.	No jurisdiction; Revelo permits court involvement if appropriate and does not affect illegality of sentence.

State v. Lawrence, 281 Conn. 147 (2007) (defines trial court jurisdiction limits and common-law basis)
State v. Parker, 295 Conn. 825 (2010) (illegal sentence exception to jurisdiction)
State v. Daniels, 207 Conn. 374 (1988) (early articulation of illegal sentence jurisdiction)
State v. Smith, 150 Conn. App. 623 (2014) (definition of illegal sentence vs. illegal manner)
State v. Delgado, 116 Conn. App. 434 (2009) (Brady claim regarding sentencing withheld evidence not within § 43-22)
State v. Revelo, 256 Conn. 494 (2001) (approved judicial involvement in plea negotiations when not affecting subsequent trial)
State v. Niblack, 220 Conn. 270 (1991) (approved judge participation in plea discussions under specific conditions)
State v. Pierce, 129 Conn. App. 516 (2011) (instructive on non-sentencing-pertinent conduct by others)
State v. Skakel, 276 Conn. 633 (2006) (Brady framework in Connecticut context)
North Carolina v. Alford, 400 U.S. 25 (1970) (Alford plea clarification cited in discussion)