State v. Hall, 303 Conn. 527

Hall pleaded guilty, under Alford, to one count of marijuana with intent to sell and two counts of violating a protective order.
At plea canvass, the court discussed rights, the Alford plea, and the sentence; defense counsel stated he had advised Hall on immigration consequences and Hall understood them.
The court asked about immigration at sentencing; prosecutor indicated Hall would be deported.
In January 2009 Hall moved to withdraw his pleas, arguing the court failed to address him personally and determine his understanding of immigration consequences under § 54-1j (a).
Appellate Court held the trial court failed to substantially comply with § 54-1j (a) by not addressing Hall personally.
Connecticut Supreme Court reverses Appellate Court, finding substantial compliance sufficient despite amendments to § 54-1j (a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court substantially complied with § 54-1j (a).	State argues substantial compliance per Malcolm suffices.	Hall argues no substantial compliance because he was not personally addressed.	Substantial compliance adequate; personal address not strictly required.
Whether the 2003 amendment to § 54-1j (a) requires strict personal addressing in all cases.	State maintains amendment preserves substantial compliance standard.	Hall contends amendment demands personal address in all circumstances.	Amendment does not disturb substantial-compliance approach; adequacy shown here.

State v. Malcolm, 257 Conn. 653 (2001) (substantial compliance suffices when warning about immigration consequences)
Lederle v. Spivey, 113 Conn.App. 177 (2009) (commonsense evaluation of record accepts notice given to defendant)
State v. Henry, 117 Conn.App. 478 (2009) (defendant cannot claim sentence surprise when no objection raised)
State v. Cazzetta, 97 Conn.App. 56 (2006) (defendant's lack of objection to terms supports upholding canvass)