State v. Santos T., 146 Conn. App. 532

Santos T. pleaded nolo contendere (2001) to two counts of first‑degree sexual assault and one count of risk of injury to a child; effective sentence 35 years, execution suspended after 10, and 35 years probation with sex‑offender registration.
Released on June 28, 2010; probation supervision commenced and conditions (including exclusion zones and limits on overnight stays) were reviewed with him.
In September 2011 he was arrested on a probation‑violation warrant for staying overnight at his former wife’s residence (where a child was present) and being near a park entrance — both prohibited.
The trial court found he violated probation and, at disposition, revoked probation and sentenced him to 15 years incarceration followed by 10 years special parole.
On appeal Santos challenged only that the sentence was an abuse of discretion/excessive (he conceded the violation finding was not contested).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused its discretion in sentencing after probation revocation	State: court appropriately considered public protection and rehabilitation; sentence within court's broad discretion	Santos: sentence excessive under the totality of circumstances; characterized violation as "technical" and argued abuse of discretion	Court affirmed: no abuse of discretion — court considered relevant factors, including monitoring, prior convictions, minimal therapy, and risk to public
Whether revocation sentence was punitive beyond original conviction	State: punishment stems from original conviction; revocation enforces consequences	Santos: sought to frame violation as technical to justify leniency	Held: revocation consequence is tied to original sentence; court’s sentence not excessive

State v. Maurice M., 31 A.3d 1063 (Conn. 2011) (distinguishes evidentiary and dispositional phases of revocation hearings)
State v. Benjamin, 9 A.3d 338 (Conn. 2010) (standards for revocation proceedings)
State v. Rodriguez, 23 A.3d 826 (Conn. App. 2011) (abuse of discretion standard at sentencing phase of revocation)
State v. Faraday, 842 A.2d 567 (Conn. 2004) (probation revocation considerations: rehabilitation and public protection)
State v. Hill, 773 A.2d 931 (Conn. 2001) (failure to comply with probation conditions supports revocation)
State v. Fagan, 905 A.2d 1101 (Conn. 2006) (appellate review of sentencing discretion)
State v. Ricketts, 57 A.3d 893 (Conn. App. 2012) (revocation as continuing consequence of original conviction)
State v. Mapp, 984 A.2d 108 (Conn. App. 2009) (affirming revocation where record supports discretion)