173 Conn. App. 64
Conn. App. Ct.2017Background
- Defendant Tauren Williams-Bey filed a motion to correct an illegal sentence in the Hartford Superior Court; the trial court dismissed the motion for lack of jurisdiction.
- The Appellate Court initially reversed, finding the trial court’s judgment form improper and directing entry of judgment denying the motion to correct an illegal sentence (State v. Williams-Bey, 167 Conn. App. 744 (2016)).
- After the Appellate Court decision, the Connecticut Supreme Court decided State v. Delgado and State v. Boyd, clarifying jurisdictional limits over motions to correct illegal sentences.
- The Supreme Court sua sponte ordered the Appellate Court to reconsider its ruling in light of Delgado and Boyd.
- On reconsideration, the Appellate Court concluded Delgado controlled and affirmed the trial court’s dismissal of the motion to correct an illegal sentence.
- The Appellate Court therefore affirmed the trial court’s dismissal, holding it lacked jurisdiction to hear the motion under the principles announced in Delgado.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court had jurisdiction to entertain the motion to correct an illegal sentence | State: trial court properly dismissed for lack of jurisdiction | Williams-Bey: trial court had jurisdiction and relief was available | Held: trial court lacked jurisdiction; dismissal affirmed |
| Whether the Appellate Court’s earlier remedy (directing entry of judgment denying the motion) was proper | State: remedy was improper after Delgado | Williams-Bey: earlier Appellate Court decision was correct | Held: Delgado controls; earlier Appellate Court decision reconsidered and reversed insofar as it disturbed trial court dismissal |
| Effect of State v. Delgado and State v. Boyd on motions to correct illegal sentence | State: Delgado/Boyd narrow jurisdiction; support dismissal | Williams-Bey: those cases do not permit dismissal in this instance | Held: Delgado/Boyd govern; they constrain trial court jurisdiction and require dismissal |
Key Cases Cited
- State v. Delgado, 323 Conn. 801 (Conn. 2016) (clarified limits on trial court jurisdiction over motions to correct illegal sentence)
- State v. Boyd, 323 Conn. 816 (Conn. 2016) (companion decision reinforcing Delgado’s jurisdictional rule)
- State v. Williams-Bey, 167 Conn. App. 744 (Conn. App. 2016) (Appellate Court’s original decision remanded for reconsideration in light of Delgado and Boyd)