State v. Simpson, 329 Conn. 820

Simpson entered an Alford guilty plea to murder and admitted a probation violation; plea was canvassed and accepted by the trial court.
After plea acceptance, Simpson wrote letters and, through counsel, filed a motion to withdraw the plea asserting ineffective assistance, lack of understanding of the charge, coercion by counsel, and requesting new counsel and an evidentiary hearing.
At sentencing, the trial court addressed Simpson on the record, gave him an opportunity to explain, reviewed the prior plea canvass transcript with him, and asked open-ended questions about why he wanted to withdraw.
Simpson admitted his motivation was effectively a change of heart ("buyer’s remorse") and reiterated complaints about counsel, but the court found the plea voluntary and denied withdrawal and any evidentiary hearing; it then imposed sentence.
The Appellate Court reversed, holding the trial court abused its discretion by not holding an evidentiary hearing on plea withdrawal and not adequately inquiring into the request for new counsel. The state appealed to the Connecticut Supreme Court.
The Connecticut Supreme Court reversed the Appellate Court, holding the trial court had conducted an adequate plea-withdrawal hearing (so no further evidentiary hearing was required) and was not required to hold a separate hearing on the request for new counsel because the complaints were insubstantial.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Simpson)	Held
Whether the trial court was required to hold an evidentiary hearing on motion to withdraw plea	No; trial court conducted a hearing and Simpson’s counsel conceded lack of grounds	Yes; alleged lack of understanding of the nature of the charge and ineffective assistance warranted an evidentiary hearing	Trial court conducted an adequate hearing; no further evidentiary hearing required (reversed Appellate Court)
Whether the trial court was required to hold a hearing/inquiry into request for new counsel	No; complaints were insubstantial and did not require inquiry	Yes; alleged breakdown with counsel and ineffective assistance required inquiry/separate hearing	No hearing required; complaints were not "seemingly substantial" and denial was not abuse of discretion

State v. Anthony D., 320 Conn. 842 (2016) (trial court must afford defendant reasonable opportunity to present factual basis for plea-withdrawal motion; no automatic duty to hold evidentiary hearing)
State v. Watson, 198 Conn. 598 (1986) (plea-withdrawal hearing may be limited; colloquy and opportunity to present argument can suffice)
State v. Robinson, 227 Conn. 711 (1993) (trial court need not inquire into insubstantial complaints about court-appointed counsel)
LaReau v. Warden, 161 Conn. 303 (1971) (counsel’s candid advice that defendant has little chance at trial is not coercion)
Krevis v. Bridgeport, 262 Conn. 813 (2003) (trial courts have inherent case-management authority)
State v. Montanez, 277 Conn. 735 (2006) (no practical significance between being labeled accessory or principal for criminal responsibility)
North Carolina v. Alford, 400 U.S. 25 (1970) (defendant may enter guilty plea while maintaining claim of innocence when evidence strongly supports conviction)