Summary
The Supreme Court of Connecticut held that a remand to the habeas court for findings on cause and prejudice was unnecessary because the petitioner failed to show that the habeas court abused its discretion in denying certification to appeal. The court upheld the rejection of the petitioner's claim that his guilty plea was not knowing, voluntary, and intelligent due to medication-related impairment, concluding that the record lacked persuasive evidence of incompetence or impaired understanding.
Holdings
- A remand to the habeas court for findings on cause and prejudice was unnecessary because, regardless of whether cause and prejudice existed, Taylor failed to demonstrate that the habeas court abused its discretion in denying certification to appeal.
- The habeas court did not abuse its discretion in denying Taylor's petition for certification to appeal because his claims lacked a plausible basis for appellate review.
- The fact that a defendant is receiving medication, without evidence that it impaired the defendant's ability to understand the proceedings or assist in the defense, does not establish incompetency or invalidate a guilty plea.
- Taylor failed to establish that his guilty plea was not knowing, voluntary, and intelligent.
Questions Presented
- Whether the Appellate Court properly remanded the case to the habeas court for a finding of cause and prejudice excusing Taylor's procedural default.
- Whether Taylor demonstrated that the habeas court abused its discretion in denying certification to appeal.
- Whether the evidence supported Taylor's claims that the trial court should have independently inquired into his competency to plead guilty and that the plea canvass was inadequate because it did not sufficiently address his medication.
Disposition
reversed_and_remanded
Cases Cited (20)
- Taylor v. Commissioner of Correction, 94 Conn. App. 772, 778-88, 895 A.2d 246 (2006)(followed in part; reversed in part)
- Taylor v. Commissioner of Correction, 280 Conn. 926, 926-27, 909 A.2d 524 (2006)(cited)
- Cobham v. Commissioner of Correction, 258 Conn. 30, 40, 779 A.2d 80 (2001)(followed)
- Pate v. Robinson, 383 U.S. 375, 385, 86 S. Ct. 836, 15 L. Ed. 2d 815 (1966)(applied)
- State v. Watson, 198 Conn. 598, 605, 504 A.2d 497 (1986)(applied)
- Duperry v. Solnit, 261 Conn. 309, 335, 803 A.2d 287 (2002)(followed)
- Hutton v. Commissioner of Correction, 102 Conn. App. 845, 853, 928 A.2d 549 (2007)(followed)
- Lozada v. Deeds, 498 U.S. 430, 431-32, 111 S. Ct. 860, 112 L. Ed. 2d 956 (1991)(adopted)
- Copas v. Commissioner of Correction, 234 Conn. 139, 150-51, 662 A.2d 718 (1995)(followed)
- State v. Johnson, 253 Conn. 1, 20-22, 751 A.2d 298 (2000)(followed)
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Court Document
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