State v. Washington

(AC 47703) (Conn. App. May 19, 2026) · Connecticut Appellate Court · May 19, 2026 · No. AC 47703

Summary

The Connecticut Appellate Court affirmed the denial of Jayvell J. Washington’s motion to withdraw his guilty plea to assault in the second degree and criminal possession of a firearm. The court held that Washington failed to show prejudice from alleged ineffective assistance of counsel and failed to substantiate his claim that the state suppressed material evidence in violation of Brady v. Maryland. The court also declined to review an inadequately briefed claim that the facts did not support a guilty verdict.

Holdings

  1. A defendant seeking to withdraw an accepted guilty plea under Practice Book § 39-27 (4) on the basis of ineffective assistance must provide facts proving deficient performance and a sufficient connection between counsel's alleged ineffectiveness and the plea's involuntary or unintelligent character, including prejudice showing that the defendant would have insisted on going to trial. Bare assertions that counsel failed to obtain complete discovery do not satisfy that burden.
  2. The defendant failed to establish that his guilty plea was involuntary under Practice Book § 39-27 (2) because his alleged Brady claim consisted of conclusory assertions and did not prove that the prosecution suppressed favorable, material evidence after a defense request or that the alleged nondisclosure prejudiced his plea decision.

Questions Presented

  1. Whether the trial court abused its discretion by denying withdrawal of the guilty plea under Practice Book § 39-27 (4) based on alleged ineffective assistance of counsel for advising the defendant to plead guilty before receiving complete discovery.
  2. Whether the trial court abused its discretion by denying withdrawal of the guilty plea under Practice Book § 39-27 (2) on the ground that the plea was involuntary because the state allegedly suppressed exculpatory or impeachment evidence in violation of Brady v. Maryland.
  3. Whether the defendant separately established that the known facts could not sustain a guilty verdict; the court declined to review this inadequately briefed claim.

Disposition

affirmed

Cases Cited (18)

  • Brady v. Maryland, 373 U.S. 83, 87, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963)(followed)
  • State v. Washington, 345 Conn. 258, 262–64, 284 A.3d 280 (2022)(cited)
  • State v. Christopher R., 222 Conn. App. 763, 779, 306 A.3d 1117 (2023), cert. denied, 348 Conn. 946, 308 A.3d 34 (2024)(followed)
  • State v. Roberts, 227 Conn. App. 159, 170–71, 320 A.3d 989 (2024), aff’d, 354 Conn. 480, A.3d (2026)(followed)
  • State v. LaMotte, 210 Conn. App. 44, 60–62, 268 A.3d 162 (2022)(followed)
  • State v. Anthony D., 320 Conn. 842, 846, 851, 855, 857, 860, 134 A.3d 219 (2016)(followed)
  • State v. Morant, 13 Conn. App. 378, 384–85, 536 A.2d 605 (1988)(distinguished)
  • State v. Lameirao, 135 Conn. App. 302, 326–27, 42 A.3d 414, cert. denied, 305 Conn. 915, 46 A.3d 171 (2012)(followed)
  • State v. Lynch, 193 Conn. App. 637, 660, 220 A.3d 163 (2019), cert. denied, 335 Conn. 914, 229 A.3d 729 (2020)(followed)
  • State v. Gay, 108 Conn. App. 211, 219–20, 947 A.2d 428, cert. denied, 288 Conn. 913, 954 A.2d 186 (2008)(followed)

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