State v. Belcher

Summary

The Connecticut Supreme Court held that the sentencing court substantially relied on materially false and unreliable information when it characterized juvenile offender Keith Belcher as a member of a purported teenage “superpredator” group. The court concluded that the theory was debunked and that its use implicated racial stereotypes and improperly treated characteristics of youth as aggravating factors. The judgment denying Belcher’s motion to correct an illegal sentence was reversed, and the case was remanded for resentencing.

Holdings

1. The superpredator theory was materially false and unreliable information that a sentencing court should not consider when sentencing a juvenile offender.
2. The sentencing court substantially relied on the superpredator theory because it expressly identified the defendant as a “charter member” of the group, devoted a substantial portion of its brief sentencing remarks to the theory, and based the sentence at least in part on that characterization.
3. Reliance on the materially false and unreliable superpredator theory infected the sentencing proceeding and caused the defendant’s sentence to be imposed in an illegal manner, in violation of due process.

Questions Presented

1. Whether the sentencing court imposed the defendant’s sentence in an illegal manner by substantially relying on the materially false and unreliable superpredator theory.
2. Whether the trial court abused its discretion in denying the defendant’s motion to correct an illegal sentence on that ground.

Disposition

reversed_and_remanded