State v. Jason B., 176 Conn. App. 236

Jason B. was convicted by a jury of first‑degree sexual assault and first‑degree unlawful restraint based on incidents on Feb 21, 2006; judgment and sentence were affirmed on direct appeal.
At sentencing the court imposed 20 years (suspended after 10) for sexual assault and 5 years for unlawful restraint, ordered to run consecutively for a 25‑year effective term; the court remarked that the unlawful restraint was akin to a lesser‑included kidnapping and that kidnapping would have carried a greater sentence.
Nearly ten years later Jason filed a second motion to correct an illegal sentence, arguing the court relied on inaccurate or extrarecord information (the kidnapping reference) when ordering consecutive sentences.
The trial court dismissed the motion for lack of subject‑matter jurisdiction, concluding Jason failed to present a colorable claim that the sentence was imposed in an illegal manner; it also reached the merits (which this court treated as dicta).
On appeal the sole contested issue was whether the motion alleged a colorable claim under Practice Book § 43‑22 that the sentencing judge relied on inaccurate or extrarecord information.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had jurisdiction under Practice Book § 43‑22 to correct a sentence alleged to be imposed in an illegal manner	State: motion must allege a colorable claim that, if proven, would require correction; here dismissal was proper because defendant alleged nothing showing reliance on inaccurate or extrarecord facts	Jason: sentencing court relied on information outside the record (reference to kidnapping) so sentence was imposed in an illegal manner and must be corrected to concurrent terms	Court: Affirmed dismissal for lack of jurisdiction — defendant failed to show even a possibility that the judge relied on inaccurate or extrarecord information; statements were rhetorical and based on trial facts

State v. Delgado, 323 Conn. 801 (2016) (motion to correct illegal sentence requires a colorable claim that, if proven, would mandate resentencing)
State v. Robles, 169 Conn. App. 127 (2016) (discusses limits of trial court jurisdiction to modify a sentence after execution and scope of § 43‑22)
State v. Cruz, 155 Conn. App. 644 (2015) (distinguishes illegal sentences from sentences imposed in an illegal manner; reliance on accurate, record information required)
State v. Parker, 295 Conn. 825 (2010) (framework for evaluating sentencing claims and illegal‑manner errors)
Farmer v. Commissioner of Correction, 165 Conn. App. 455 (2016) (movement or confinement separate from another crime may support kidnapping charge)