Summary
This Connecticut Appellate Court decision addresses a defendant's direct appeal following a guilty plea to manslaughter in the first degree. The defendant argued that the trial court erred by failing to advise him that his conviction would statutorily disqualify him from earning risk reduction credits, rendering his plea involuntary. The appellate court affirmed the conviction, holding that it lacks the judicial authority to amend the governing statute to grant credit eligibility, as doing so would violate separation of powers principles. Because the defendant did not seek to withdraw his guilty plea, the court declined to rule on whether the missing advisement violated procedural rules.
Topics
Practice areas
Questions Presented
- Whether the trial court erred by failing to inform the defendant that, under General Statutes § 18‑98e, a first‑degree manslaughter conviction makes him ineligible for risk‑reduction credits, rendering his plea not knowingly and voluntarily made.
- Whether this appellate court may grant the requested relief by ordering the defendant eligible for risk‑reduction credits.
Holdings
- The court lacks authority to amend § 18‑98e and therefore cannot grant the requested relief; the judgment of the trial court is affirmed.
Key quotations
“It is axiomatic that the court itself cannot rewrite a statute to accomplish a particular result. That is the function of the legislature.” (at 81)
“The judgment is affirmed.” (at 81)
Factual background
Charles Artis pleaded guilty to first‑degree manslaughter and a motor‑vehicle offense, received a twenty‑year sentence with a suspended portion, and was not advised that the statute § 18‑98e barred him from earning risk‑reduction credits, which he claimed made his plea involuntary.
Procedural history
Defendant was charged with first‑degree manslaughter and a motor‑vehicle offense, entered a guilty plea in Superior Court, was sentenced to twenty years (with suspension) and five years probation, and appealed the conviction asserting the trial court failed to inform him that he was ineligible for risk‑reduction credits under § 18‑98e.