State v. Crawford

Summary

The Connecticut Supreme Court considered whether the defendant presented a colorable double-jeopardy claim permitting an interlocutory appeal from the denial of his motion to dismiss a first-degree manslaughter charge. The court held that a claim based on multiple punishments, rather than successive prosecution, does not support interlocutory review because the defendant may still be tried and can challenge any punishment after final judgment. The court also rejected the defendant’s collateral-estoppel argument because his prior conviction followed a guilty plea rather than a trial and acquittal, and dismissed the appeal.

Holdings

1. A claim alleging only multiple punishments, rather than successive prosecution, does not present a colorable double-jeopardy claim supporting an interlocutory appeal because the multiple-punishments protection applies to punishments imposed in a single trial and does not protect against being tried.
2. The defendant did not present a colorable collateral-estoppel claim because collateral estoppel requires an issue of ultimate fact to have been necessarily determined in the defendant's favor in a valid prior judgment, and the defendant's prior proceeding resulted in a guilty plea and conviction rather than a trial and acquittal.
3. Because the defendant's claims were not colorable double-jeopardy claims within the interlocutory-appeal exception to the final-judgment rule, the court lacked subject-matter jurisdiction over the appeal.

Questions Presented

1. Whether the defendant's claim that a later manslaughter prosecution would result in multiple punishment for the same offense was a colorable double-jeopardy claim supporting an interlocutory appeal.
2. Whether the defendant's collateral-estoppel claim based on his prior guilty plea and conviction presented a colorable double-jeopardy claim supporting interlocutory appellate jurisdiction.

Disposition

dismissed