State v. Miranda, 120 A.3d 490

Defendant Miranda was convicted of capital felony, murder, felony murder, and kidnapping arising from the killing of a single victim.
Trial court sentenced Miranda to life without parole for capital felony, plus 100 more years for other offenses, consecutive.
Appellate Court vacated the murder and felony-murder convictions as double jeopardy violations, remanding with direction to vacate those convictions.
State sought certification; issue framed on remedy for cumulative double jeopardy convictions under Polanco and Chicano lineage.
Polanco overruled Chicano for greater/lesser included offenses and endorsed vacatur; the court extended consideration to other cumulative scenarios.
Court held the Polanco vacatur remedy applies to Miranda’s cumulative felony murder conviction and affirmed the Appellate Court’s judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Polanco extends vacatur beyond greater/lesser included offenses.	Miranda argues Polanco applies to other cumulative convictions.	State contends Polanco is limited to greater/lesser included offenses and merger remains viable.	Polanco extends to other cumulative homicide convictions.
Whether vacatur is the proper remedy for Miranda's cumulative homicide convictions.	Polanco supports vacating the lesser offense when cumulative offenses violate double jeopardy.	State worries vacatur could undercut potential reinstatement if controlling conviction is overturned.	Vacatur is appropriate remedy for cumulative homicide convictions.
Whether the state could resurrect a vacated felony murder conviction if a controlling conviction is overturned.	Resurrection may be possible under analogous federal/other state practice without creating double jeopardy.	There is risk of inconsistencies or undue collateral consequences if the vacated conviction cannot be reinstated.	Remains permissible to reinstate a vacated conviction where compatible with the overturned controlling conviction.

State v. Polanco, 308 Conn. 242 (2013) (readopted vacatur remedy for cumulative double jeopardy convictions; extended beyond greater/lesser offenses)
State v. Chicano, 216 Conn. 699 (1990) (merger of convictions for greater/lesser offenses as remedy for double jeopardy)
Rutledge v. United States, 517 U.S. 292 (1996) (rejection of merger approach; supports vacatur for certain cumulative offenses)
Ball v. United States, 470 U.S. 856 (1985) (second conviction for same offense is impermissible punishment)
State v. John, 210 Conn. 652 (1989) (single incident can support multiple homicide predicates)
State v. Jones, 314 Conn. 410 (2014) (authorizes procedural reforms for double jeopardy cases; leaves broader rules to court committees)
United States v. Silvers, 90 F.3d 95 (4th Cir. 1996) (permits reinstatement of vacated conviction where necessary to preserve justice)