State v. Meikle, 146 Conn. App. 660

Clyde Meikle was convicted of murder after a 1998 jury trial for shooting Clifford Walker with a sawed-off shotgun; Meikle claimed the weapon discharged accidentally.
Meikle was sentenced to 50 years' incarceration following conviction.
He pursued multiple postconviction remedies (direct appeal, two habeas petitions) that were denied.
In April 2011 Meikle filed an amended motion to correct an illegal sentence under Practice Book § 43-22, alleging the shotgun introduced at trial was not the murder weapon and that the state concealed this from trial counsel.
The trial court held a hearing and denied Meikle’s motion; Meikle appealed and proceeded pro se at the trial-court stage after the public defender declined to file the motion.
The appellate court concluded the trial court lacked subject matter jurisdiction to consider the motion and ordered the motion dismissed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had jurisdiction to hear a motion to correct an illegal sentence alleging trial-evidence errors	Meikle argued the sentencing court relied on inaccurate information (the shotgun) used at trial, so the sentencing is tainted and subject to correction under Practice Book § 43-22	State argued the claim attacked trial proceedings/evidence, not the sentencing itself, and thus was outside the narrow scope of a § 43-22 motion	The court held the sentencing court lacked subject matter jurisdiction because the motion attacked trial-related matters (admissibility/accuracy of trial evidence), not the sentence or sentencing proceeding; the motion must target the sentencing itself to invoke § 43-22

Ajadi v. Commissioner of Correction, 280 Conn. 514 (plenary review of subject-matter-jurisdiction questions)
State v. Lawrence, 281 Conn. 147 (motion to correct must attack sentencing proceeding, not the trial)
State v. Delgado, 116 Conn. App. 434 (jurisdiction over § 43-22 motions limited to sentencing errors)
State v. Casiano, 282 Conn. 614 (appointed counsel need not file frivolous or improper motions)
State v. Meikle, 60 Conn. App. 802 (trial conviction and prior appellate history)