State v. Jones, 163 A.3d 622

Background

In 2011 Laquan Jones pleaded guilty to first‑degree assault for discharging a firearm; sentence: 10 years suspended, 5 years probation beginning December 20, 2011, with conditions forbidding new arrests and weapon possession.
On March 10, 2013 Jones was accused of shooting a victim; he was charged with carrying a pistol without a permit and a probation violation was tried in September 2013.
The trial court found the state proved Jones violated probation by committing the firearm offense and revoked probation, activating the previously suspended 10‑year sentence.
On October 29, 2013 Jones entered an Alford plea to carrying a pistol without a permit and was sentenced to four years (one year mandatory) concurrent with the 10‑year sentence.
Jones appealed the probation revocation claiming insufficient evidence, but did not timely appeal the Alford plea; he later sought leave to file a late appeal of the plea, which this court denied.
The state argued the appeal of the probation finding is moot because Jones’s Alford plea produced a conviction that conclusively established the underlying criminal conduct.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal from probation revocation is justiciable or moot after defendant’s Alford plea to the underlying crime	State: conviction by plea renders any challenge to probation violation moot because conviction conclusively establishes the conduct	Jones: appeal remains live because he later sought leave to file a late appeal and contends the trial court indicated the Alford plea would not bar his probation appeal	Appeal is moot: Alford plea is a conviction that conclusively establishes the criminal conduct and eliminates a live controversy; no timely appeal of the plea was taken, so the probation challenge cannot proceed
Whether trial court orally assured plaintiff that entering an Alford plea would preserve right to appeal probation finding	Jones: court allegedly indicated plea would not affect his probation appellate rights	State: record does not show any such assurance; court only noted plea was entered despite factual dispute	Court found no record promise; transcript shows court characterized plea as Alford to reflect factual contest and plea agreement use
Whether a court can assure a result contrary to binding precedent (i.e., preserve appealability despite conviction)	Jones: contends preservation was attempted via plea colloquy	State: trial court cannot override established law that conviction moots probation appeal	Court: trial court cannot promise a result that conflicts with binding precedent; precedent controls and renders appeal moot
Whether Jones falls within narrow T.D. exception that preserves review despite subsequent conviction	Jones: implied exception because of plea circumstances and attempted late appeal	State: Jones did not timely appeal the conviction; late‑appeal motion denied; exception inapplicable	Court: T.D. exception not met; because Jones did not timely appeal his conviction, the probation appeal is moot

Key Cases Cited

State v. T.D., 286 Conn. 353 (2008) (conviction — including guilty or Alford plea — eliminates controversy over probation violation)
State v. Rodriguez, 320 Conn. 694 (2016) (conviction of new crime after probation finding renders challenge moot; T.D. narrow exception discussed)
State v. McElveen, 261 Conn. 198 (2002) (guilty plea conviction conclusively establishes underlying conduct for probation purposes)
In re Allison G., 276 Conn. 146 (2005) (mootness requires live controversy throughout appeal)
North Carolina v. Alford, 400 U.S. 25 (1970) (Alford plea recognized as plea entered while maintaining innocence but treated as guilty plea)