State v. Hurdle, 350 Conn. 770

Defendant Marcus Hurdle was convicted of robbery in the first degree and conspiracy to commit robbery in the first degree after a guilty plea in Connecticut.
He sought presentence confinement credit for time spent in jail before sentencing, some of which overlapped with sentences he was serving from unrelated cases.
The trial court denied his request for specific jail credit on the judgment mittimus, stating it lacked authority to do so under Conn. Gen. Stat. § 18-98d, and deferred to the Commissioner of Correction for calculation of credit.
Defendant unsuccessfully moved to withdraw his plea, arguing there was no meeting of the minds about jail credit upon which he relied in taking the plea.
The Appellate Court affirmed the trial court, holding the court lacked authority to direct the Commissioner on jail credit and that the plea agreement did not guarantee such credit.
On further appeal, the Connecticut Supreme Court addressed whether trial courts have authority to direct the Commissioner to apply presentence confinement credit, and whether the plea agreement was ambiguous as to jail credit.

Issue	Hurdle's Argument	State's Argument	Held
Can trial courts direct the DOC Commissioner to apply jail credit?	Statute does not deprive trial courts of inherent authority.	Exclusive authority lies with Commissioner under § 18-98d.	Trial courts have discretionary authority to order presentence credit on mittimus.
Did the plea agreement guarantee jail credit for unrelated cases?	Agreement included such credit or was ambiguous.	No evidence of such agreement or understanding.	No agreement for such credit; plea did not guarantee that credit.
Is the plea void due to no meeting of the minds on jail credit?	Lack of shared understanding on credit voids agreement.	Defendant’s belief was subjective and unreasonable.	No voiding; defendant’s subjective belief was unreasonable under the circumstances.
Should case be remanded for court to exercise discretion?	Yes, since trial court wrongly believed it lacked authority.	No, authority resides with Commissioner, not trial court.	Remanded for trial court to exercise discretion on presentence confinement credit.

State v. Angel M., 337 Conn. 655 (sentencing discretion is broad within statutory limits)
Washington v. Commissioner of Correction, 287 Conn. 792 (executive manages sentence once imposed, but does not hold exclusive authority for jail credit)
Hammond v. Commissioner of Correction, 259 Conn. 855 (presentence credit is statutory but court may consider pre-sentence incarceration as a factor)
State v. Bischoff, 337 Conn. 739 (sentencing power balance between judiciary and legislature)
State v. Kallberg, 326 Conn. 1 (plea agreements interpreted by objective intent, principles of contract law)