State v. Miller
186 Conn. App. 654
| Conn. App. Ct. | 2018Background
- In 1991 Omar Miller, age 19 at the time of the offense, pleaded guilty to murder and was sentenced in absentia to 35 years after escaping custody; he began serving the sentence after recapture in 1997.
- In June 2016 Miller filed a pro se motion to correct an illegal sentence under Practice Book § 43-22, arguing his 35-year sentence violated state constitutional protections against cruel and unusual punishment because the court failed to consider mitigating factors tied to youth (he sought relief for individuals under 20).
- On June 30, 2016 the trial court, sua sponte and without a hearing, denied the motion; Miller appealed and later requested compliance with Practice Book § 64-1 (a written or oral statement of decision).
- The court held a September 29, 2016 proceeding to place its reasons on the record and signed the transcript, but that proceeding occurred after the court had already decided to deny the motion.
- Miller argued he was entitled to a hearing and an opportunity to develop an evidentiary record (including expert brain/psychology testimony) because he raised a novel state-constitutional claim extending juvenile sentencing protections to persons under twenty.
- The appellate court reversed, holding the trial court improperly denied the motion without providing a meaningful opportunity to be heard and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument (Miller) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether a hearing is required before disposing of a motion to correct an illegal sentence under Practice Book § 43-22 | § 43-22 requires an opportunity to be heard; court must allow a hearing before denying the motion | The court’s summary denial was permissible; no hearing was required in this context | Hearing required — § 43-22 contains no authorization for summary disposal and no authority authorizes disposing without a hearing |
| Whether the September 29, 2016 proceeding satisfied the right to be heard | That proceeding occurred after denial and was insufficient; Miller needed a meaningful opportunity to present evidence and witnesses | The September 29 proceeding (oral statement and brief argument) constituted an adequate hearing | Insufficient — court had already decided the motion; the proceeding merely memorialized the prior ruling and did not afford a meaningful opportunity to be heard |
| Whether Miller was entitled to develop an evidentiary record for his novel state-constitutional claim (extend juvenile protections to <20) | He should be allowed to present biographical, sociological, psychological evidence and expert testimony to support first-impression claim under state constitution | The state did not dispute the general right to a hearing but maintained the court had already examined the motion | Miller must be allowed to develop a record on remand; the trial court’s summary denial frustrated his right to present relevant evidence |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for offenders under 18 violates the Eighth Amendment)
- State v. Riley, 315 Conn. 637 (2015) (discusses juvenile sentencing jurisprudence and the role of psychology/brain science)
- Haughey v. Commissioner of Correction, 173 Conn. App. 559 (2017) (recognizes juvenile offender as under 18 for Eighth Amendment sentencing analysis)
- State v. Casiano, 282 Conn. 614 (2007) (addresses right to counsel in postconviction proceedings)
- Green v. Commissioner of Correction, 184 Conn. App. 76 (2018) (interpreting Practice Book provisions to permit summary disposition of habeas petitions in limited circumstances)