State v. McClean, 144 A.3d 490

Michael McClean pleaded guilty under the Alford doctrine in 1998 to murder; the state recommended a 30-year sentence and withdrew other charges and enhancements.
The court sentenced McClean to 30 years incarceration on March 20, 1998; the parties waived a presentence investigation report.
McClean filed a motion to correct an illegal sentence in 2013 (self‑represented) and, later, counsel filed a supporting brief (2014), arguing the sentence violated Miller and Graham because no individualized youth‑based sentencing consideration occurred and there is no meaningful opportunity for release based on maturity/rehabilitation.
The trial court (Alexander, J.) heard argument and dismissed the motion in a July 2014 memorandum, concluding Miller and Graham applied only to mandatory life without parole at the time and thus the court lacked jurisdiction to grant relief.
The Appellate Court reviewed jurisdiction and merits, concluding the trial court had jurisdiction to decide the claim, but that McClean’s 30‑year sentence did not violate Miller as interpreted in subsequent Connecticut precedent; the proper disposition was denial (not dismissal) of the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court had jurisdiction to entertain a motion to correct claiming a sentence was imposed illegally under Miller	Motion to correct was a proper vehicle to challenge sentencing procedure; court can decide whether sentence was imposed illegally	Trial court argued it lacked jurisdiction to provide relief because Miller/Graham applied only to mandatory life without parole at that time	Court had jurisdiction to decide the claim; dismissal was improper — motion should have been denied on the merits rather than dismissed
Whether McClean’s 30‑year sentence violated the Eighth Amendment under Miller (youth‑based individualized sentencing and prohibition on life‑without‑parole analogues)	McClean argued absence of individualized consideration of youth factors and that 30 years functionally equates to life without parole for a juvenile	State argued 30 years did not amount to an unconstitutional term of years and McClean would be eligible for parole under subsequent statute	Court held McClean’s sentence did not violate Miller as construed by Connecticut precedent (not unconstitutional); judgment reversed and remanded with direction to deny the motion

Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (mandatory life without parole for juveniles unconstitutional)
Graham v. Florida, 560 U.S. 48 (U.S. 2010) (juveniles convicted of nonhomicide crimes entitled to some meaningful opportunity for release)
State v. Logan, 160 Conn. App. 282 (Conn. App. 2015) (term‑of‑years sentence for a juvenile did not violate Miller)
Casiano v. Commissioner of Correction, 317 Conn. 52 (Conn. 2015) (discretionary life without parole and de facto life terms can violate Miller)
State v. Riley, 315 Conn. 637 (Conn. 2015) (state application of Miller to certain lengthy sentences)