State v. Fletcher, 183 Conn. App. 1

Darryl Fletcher was released on probation in 2011 following a lengthy sentence; special conditions included drug screening, treatment, and verifiable employment.
In November 2014 a violation-of-probation warrant was signed; it was not served until October 2015.
At a May 2, 2016 revocation hearing the trial court found Fletcher violated multiple probation conditions (failed to verify employment, failed programs, positive drug tests).
In the dispositional phase the court revoked probation and sentenced Fletcher to eighteen months incarceration.
Fletcher appealed only the dispositional claim that the court relied on a factual inference (that he eluded service for ~1 year) not supported by the record and sought a new sentencing hearing.
The State moved to dismiss as moot after Fletcher completed his sentence; the court considered collateral-consequences and Golding review of the unpreserved due-process claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness — can appeal proceed after sentence expired?	State: appeal is moot because no practical relief (sentence served).	Fletcher: collateral-consequences and capable-of-repetition-but-evade-review exceptions apply; a new dispositional hearing could provide practical future relief.	Court retained jurisdiction under the collateral-consequences exception (reasonable possibility of future prejudice to employment/standing and sentencing consequences).
Whether court relied on improper/non‑record fact at disposition	State: (implicit) court’s inference about delay and efforts to serve warrant was supported by testimony.	Fletcher: court improperly inferred he eluded arrest for a year; no evidence officers searched or he attempted to avoid arrest; reliance infected sentencing.	Under Golding the court found the inference had minimal indicium of reliability (probation officer testimony about warrant issuance, unusual delay, defendant’s evasiveness) and that the court did not rely on demonstrably false information; no due‑process violation.

Middlebury v. Connecticut Siting Council, 326 Conn. 40 (Conn. 2017) (mootness & practical relief principles)
State v. McElveen, 261 Conn. 198 (Conn. 2002) (probation-revocation appeal not moot due to collateral consequences)
State v. Preston, 286 Conn. 367 (Conn. 2008) (dispositional-phase claims can survive mootness; collateral consequences from revocation)
State v. Altajir, 303 Conn. 304 (Conn. 2012) (sentencing information must have minimal indicium of reliability)
State v. Huey, 199 Conn. 121 (Conn. 1986) (due process limits on sentencing information reliability)
State v. Berger, 249 Conn. 218 (Conn. 1999) (trier may draw reasonable inferences from evidence)
State v. Smith, 207 Conn. 152 (Conn. 1988) (revocation as a blemish causing collateral consequences)
State v. Golding, 213 Conn. 233 (Conn. 1989) (framework for appellate review of unpreserved constitutional claims)