Wright v. Commissioner of Correction
68 A.3d 1184
Conn. App. Ct.2013Background
- Petitioner Travis Wright seeks certiorari after habeas court denied petition for writ of habeas corpus and for certification to appeal.
- Convicted of first-degree manslaughter; sentence 17 years; conviction affirmed on direct appeal.
- Habeas petition challenged trial confession as untrustworthy and claimed ineffective assistance of trial and appellate counsel.
- Defense theory focused on confession being false; trial relied on corroborating details and diagrams drawn during interrogation.
- Habeas court rejected innocence claim and found no newly discovered evidence; denial of certification to appeal upheld.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did trial counsel provide ineffective assistance? | Wright contends trial counsel failed to obtain psychiatric/psychological evaluation and to present Leo's testimony. | Moniz pursued a coherent strategy focusing on the confession's unreliability and did present relevant testimony. | No reversible error; strategy deemed reasonable and not deficient. |
| Is the confession trustworthy and sufficiently corroborated? | Confession was uncorroborated and unreliable. | Confession corroborated by body discovery and injury details; corpus delicti satisfied. | Confession corroborated; not untrustworthy for admission. |
| Was appellate counsel ineffective for not raising uncorroboration claim on direct appeal? | Failure to raise claim prejudiced Wright. | Appellate strategy to avoid weak issues; not prejudicial given lack of merit on corroboration. | No abuse of discretion; not prejudicial. |
| Did Wright establish actual innocence with newly discovered evidence? | Kapoor’s testimony on spatial/perceptual deficits should be newly discovered evidence. | Evidence was readily discoverable; even if newly discovered, it did not prove innocence. | No actual innocence; no abuse of habeas discretion. |
Key Cases Cited
- State v. Hafford, 252 Conn. 274 (2000) (corpus delicti corroboration standard governing confession admissibility)
- State v. Harris, 215 Conn. 189 (1990) (corpus delicti corroboration requirement for extrajudicial confession)
- Lozada v. Deeds, 498 U.S. 430 (1991) (standard for abuse of discretion in certiorari to appeal; Lozada factors)
- Simms v. Warden, 229 Conn. 178 (1994) (requirement to show abuse of discretion before reviewing habeas merits)
- Castonguay v. Commissioner of Correction, 300 Conn. 649 (2011) (standard for appellate review of habeas decisions; mootness of issues)
- Opper v. United States, 348 U.S. 84 (1954) (corpus delicti corroboration principle source for corroboration rule)
- Miller v. Commissioner of Correction, 242 Conn. 745 (1997) (two-step test for freestanding actual innocence claim; newly discovered evidence requirement)
- Simms v. Warden, 230 Conn. 608 (1994) (incorporation of Lozada factors into habeas review)