State v. Delgado
151 A.3d 345
| Conn. | 2016Background
- Delgado was convicted (for crimes committed at age 16) and sentenced in 1996 to a 65‑year term (effectively life without parole at that time).
- On direct appeal this court affirmed the murder conviction and preserved the 65‑year aggregate sentence after vacating a separate weapons conviction.
- In 2014 Delgado filed a Practice Book §43‑22 motion to correct his sentence, arguing his sentence violated the Eighth Amendment because the sentencing court did not consider youth‑related mitigating factors and he had no meaningful opportunity for release.
- While that motion was pending, Connecticut enacted P.A. 15‑84 (codified at Conn. Gen. Stat. §§54‑125a, 54‑91g), making many juvenile offenders parole‑eligible and requiring youth‑based consideration at sentencing prospectively for certain felonies.
- The trial court dismissed Delgado’s motion for lack of jurisdiction. The Supreme Court affirmed, holding that because Delgado is now parole‑eligible under P.A. 15‑84 Miller‑based relief (resentencing) is not required and the court lacks jurisdiction to order resentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court had jurisdiction to correct Delgado’s sentence under Practice Book §43‑22 | Delgado: his sentence was illegal or imposed in an illegal manner because the court failed to consider youth mitigating factors under Miller, requiring resentencing | State: after P.A. 15‑84 Delgado is parole‑eligible, so Miller/Riley do not require resentencing and the court lacks jurisdiction | Court held Delgado’s motion no longer raised a colorable claim requiring resentencing; trial court lacked jurisdiction to correct the sentence |
| Whether Miller requires resentencing when a juvenile’s sentence includes a parole opportunity | Delgado: Miller/Riley/Casiano mandate an individualized, youth‑focused resentencing for juvenile sentences equivalent to life | State: Miller’s requirement to consider youth applies only to life without parole; parole eligibility remedies Miller concerns | Held Miller’s mitigation requirement applies only where life without parole (or functional equivalent) is imposed; parole eligibility can satisfy the constitutional concern |
| Whether P.A. 15‑84 §2 (youth consideration at sentencing) applies retroactively | Delgado: statute’s dual requirements (parole + Miller‑compliant hearing) imply resentencing for those previously sentenced | State: §2 is prospective; text and legislative history indicate no retroactive application | Held §2 is not retroactive; Delgado cannot obtain resentencing under §2 |
| Whether Montgomery requires resentencing rather than parole eligibility as remedy | Delgado: Montgomery doesn’t limit remedies to parole eligibility and does not preclude resentencing | State: Montgomery permits states to remedy Miller violations by providing parole consideration rather than universal resentencing | Held Montgomery allows parole eligibility to be a constitutionally adequate remedy; resentencing is not categorically required |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory life without parole for juveniles violates Eighth Amendment; sentencer must consider youth as mitigation)
- Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller announced a substantive rule applicable retroactively; parole consideration may remedy Miller violations)
- Roper v. Simmons, 543 U.S. 551 (2005) (barred capital punishment for juvenile offenders)
- Graham v. Florida, 560 U.S. 48 (2010) (barred life without parole for juvenile nonhomicide offenders; requires meaningful opportunity for release)
- State v. Riley, 315 Conn. 637 (2015) (interpreting Miller to require consideration of youth when sentencing juveniles to life or its functional equivalent)
- Casiano v. Commissioner of Correction, 317 Conn. 52 (2015) (held Miller principles apply retroactively in collateral proceedings)
- State v. Parker, 295 Conn. 825 (2010) (trial court may correct illegal sentences or those imposed in an illegal manner under Practice Book §43‑22; jurisdictional limits explained)
- State v. Williams‑Bey, 167 Conn. App. 744 (2016) (Appellate Court held parole opportunity under P.A. 15‑84 can provide constitutionally adequate remedy for Miller violations)