State v. Simpson
150 A.3d 699
| Conn. App. Ct. | 2016Background
- Defendant Earl Simpson entered an Alford plea to murder (charged under § 53a-54a and § 53a-8 as an accessory) on September 19, 2014; plea canvass did not reference accessorial elements.
- Prosecutor’s factual proffer at plea suggested both principal and accessory theories and referenced a defendant statement admitting he was “one of the shooters.”
- Defendant later sent two handwritten letters to the court and, through counsel, filed a motion to withdraw the plea claiming he did not understand the nature of the charge, that counsel was ineffective (failed to explain accessory versus principal liability, pressured him), and requesting new counsel and an evidentiary hearing.
- At sentencing, the court reviewed the plea transcript and letters, questioned the defendant briefly, concluded the defendant’s claims were conclusory or amounted to buyer’s remorse, denied an evidentiary hearing and the plea-withdrawal request, and imposed 32.5 years (25 years mandatory).
- The Appellate Court found the plea and file did not conclusively refute the defendant’s assertions that he lacked understanding of the accessorial nature of the charge and that he had substantial complaints about counsel; the court thus held an evidentiary hearing and inquiry into substitution of counsel were required.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Simpson) | Held |
|---|---|---|---|
| Whether the trial court abused its discretion by denying plea-withdrawal and failing to hold an evidentiary hearing | The plea canvass and file show the defendant understood the charge and sentence; plea was voluntary; no hearing needed because claims were conclusory and belied by transcript | He did not understand the accessorial nature of the murder charge and asked for an evidentiary hearing to show plea was not knowing/voluntary | Reversed: an evidentiary hearing was required because defendant’s letters raised specific, nonconclusory claims not conclusively refuted by the record |
| Whether the court violated or abused its discretion by failing to inquire into defendant’s complaints about counsel or appoint new counsel | No further inquiry was necessary; plea transcript indicated defendant was satisfied with counsel | Defendant raised substantial complaints (ineffective assistance, pressured to plead, failure to explain elements) and requested new counsel in letters | Reversed: court abused its discretion by failing to inquire into the substantial complaints and must evaluate request for substitute counsel on remand |
| Whether the plea canvass sufficiently explained the nature of the charge given accessorial liability in information | The substantive crime was murder and the court adequately apprised defendant; the prosecutor’s factual proffer and information put defendant on notice of accessorial theory | The plea canvass never explained accessorial elements; defendant said counsel failed to explain difference between accessory and principal | Held for defendant on this point: accessorial nature is material to knowing plea; plea record did not conclusively refute defendant’s claims |
| Whether defendant’s post-plea statements amounted merely to change of heart (no basis for withdrawal) | Defendant’s admissions at sentencing showed he changed his mind; plea transcript controls | Letters and motion raised specific grounds (lack of knowledge of charge, ineffective counsel) that cannot be treated as mere remorse | Held for defendant: record did not conclusively show mere buyer’s remorse; further factfinding required |
Key Cases Cited
- North Carolina v. Alford, 400 U.S. 25 (1970) (establishes that a defendant may enter a guilty plea while maintaining innocence if evidence strongly favors conviction)
- Boykin v. Alabama, 395 U.S. 238 (1969) (plea must be voluntary and knowing; waiver of core constitutional rights must appear on record)
- State v. Faraday, 268 Conn. 174 (2004) (Alford pleas carry same consequences as guilty pleas; discussion of their effect)
- State v. Anthony D., 320 Conn. 842 (2016) (defendant bears burden to show plausible reason to withdraw plea; court’s discretion in holding hearing)
- State v. Barnwell, 102 Conn. App. 255 (2007) (presumption that counsel explained elements may apply absent positive suggestion to the contrary)