State v. McClean, 164 A.3d 35

Defendant Michael McClean filed a motion to correct an illegal sentence in the Hartford Superior Court.
The trial court dismissed McClean’s motion, concluding it lacked merit (or jurisdiction under the then-applicable law as later interpreted).
The Appellate Court originally reversed and remanded, concluding the trial court’s judgment form was improper and directing denial of the motion to correct. See State v. McClean, 167 Conn. App. 781 (2016).
After the Appellate Court’s decision, the Connecticut Supreme Court decided State v. Delgado and State v. Boyd, clarifying jurisdictional limits on motions to correct illegal sentence.
The Supreme Court sua sponte ordered the Appellate Court to reconsider McClean in light of Delgado and Boyd.
On reconsideration, the Appellate Court concluded it was constrained by Delgado and affirmed the trial court’s dismissal of McClean’s motion.

Issue	Plaintiff's Argument (State)	Defendant's Argument (McClean)	Held
Whether the trial court had jurisdiction to hear McClean’s motion to correct an illegal sentence	The state argued the trial court properly dismissed the motion; it lacked a cognizable claim under the motion to correct vehicle after Delgado	McClean argued the trial court had jurisdiction and his sentence was illegal and thus correctable	The court held, constrained by State v. Delgado, the trial court properly dismissed the motion and its judgment is affirmed

State v. McClean, 167 Conn. App. 781 (Conn. App. 2016) (Appellate Court’s original disposition and remand concerning form of judgment on motion to correct)
State v. Delgado, 323 Conn. 801 (Conn. 2016) (Supreme Court limiting trial court jurisdiction over certain motions to correct illegal sentence)
State v. Boyd, 323 Conn. 816 (Conn. 2016) (related Supreme Court decision clarifying scope of motions to correct illegal sentence)