State of Connecticut v. Michael Burnell, 290 Conn. 634

Summary

The Supreme Court of Connecticut held that an administrative driver's license suspension under General Statutes § 14-227b is not a criminal conviction or prosecution for purposes of federal or state double jeopardy protections. The court therefore affirmed the defendant's conviction for operating a motor vehicle under the influence in violation of § 14-227a(a), rejecting his argument that the prior administrative suspension barred the criminal prosecution.

Holdings

1. An administrative license suspension under General Statutes § 14-227b is civil in nature, does not constitute a criminal conviction or prosecution, and therefore does not bar a subsequent criminal prosecution under § 14-227a(a) for the same conduct.
2. The defendant's state constitutional double-jeopardy claim fails because the administrative proceedings were civil and did not produce a criminal prosecution or conviction, and Connecticut's constitutional protection against double jeopardy mirrors rather than exceeds the federal protection in this context.

Questions Presented

1. Whether an administrative driver's-license suspension under General Statutes § 14-227b constitutes a criminal conviction for purposes of the federal Double Jeopardy Clause and therefore bars a subsequent prosecution under § 14-227a(a).
2. Whether the Connecticut Constitution provides greater double-jeopardy protection that would treat the administrative suspension as a criminal prosecution or conviction and bar the subsequent prosecution.

Disposition

affirmed