State v. Boyd, 323 Conn. 816

Summary

The Connecticut Supreme Court affirmed the dismissal for lack of jurisdiction of Ray Boyd’s motion to correct an illegal sentence. Boyd, who committed murder at age seventeen and received a fifty-year sentence without parole, argued that recent juvenile-sentencing decisions required resentencing; the court held that statutory changes making him eligible for parole removed the basis for a colorable Miller-related claim.

Holdings

1. A trial court has jurisdiction under Practice Book § 43-22 only when the defendant alleges a colorable claim that the sentence is illegal or was imposed in an illegal manner.
2. After the enactment of Public Act 15-84, a juvenile offender who is eligible for parole cannot claim that a sentence of fifty years' imprisonment is life imprisonment, or its equivalent, without parole for purposes of Miller-based resentencing.

Questions Presented

1. Whether the trial court had jurisdiction over the defendant's motion to correct an illegal sentence after statutory changes made him eligible for parole.
2. Whether the defendant could still assert a colorable Miller-based claim that his sentence was illegal or imposed in an illegal manner and therefore required resentencing.

Disposition

affirmed