Summary
This Connecticut Supreme Court case addresses whether a trial court has the authority under General Statutes § 18-98d to direct the commissioner of correction to apply specific presentence confinement credit to a defendant's sentence. The court held that the statute does not grant exclusive authority to the commissioner and that trial courts possess discretionary authority to include such directives on a judgment mittimus. Additionally, the court affirmed that the defendant's plea agreement did not guarantee presentence confinement credit for time served in unrelated cases, rejecting his claim that the agreement was void due to a lack of mutual assent. Consequently, the court reversed the Appellate Court's decision regarding the trial court's authority and remanded the case for further proceedings on the credit issue.
Topics
Practice areas
Questions Presented
- Whether General Statutes § 18-98d gives the commissioner of correction exclusive authority to calculate and apply presentence confinement credit, thereby depriving the trial court of authority to direct the commissioner to apply specified credit dates.
- Whether the defendant's plea agreement included an agreement that he would receive presentence confinement credit for time spent serving sentences in unrelated cases.
- Whether the plea agreement was void for lack of a meeting of the minds because the defendant believed he would receive that credit.
Holdings
- General Statutes § 18-98d does not confer exclusive authority on the commissioner to calculate and apply presentence confinement credit. A trial court has discretionary authority to include on a judgment mittimus an order directing the commissioner to apply, consistent with § 18-98d (a) (1) (A), credit for specified qualifying dates of presentence confinement.
- The plea agreement did not include an agreement that the defendant would receive presentence confinement credit for time spent serving sentences in the unrelated Ansonia-Milford and New Haven cases. The defendant's subjective belief that he would receive that credit was objectively unreasonable, so the plea agreement was not void for lack of a meeting of the minds and he was not entitled to withdraw his pleas.
Key quotations
“In summary, we conclude that the trial court has the discretionary authority to direct the commissioner to apply specific presentence confinement dates to a sentence.” (350 Conn. at 792)
“The commissioner has the ultimate and exclusive responsibility to apply that credit, and any additional presentence credit if applicable, as well as to calculate the defendant’s release date.” (350 Conn. at 792 n.18)
“We therefore reject this claim.” (350 Conn. at 797)
Factual background
Hurdle was charged with offenses arising from a robbery and related events in West Haven and New Haven. Before resolving the present case, he was serving sentences or awaiting disposition in unrelated Ansonia-Milford and New Haven matters, and he sought presentence confinement credit for specified periods. He later entered Alford pleas under an agreement providing for a twelve-year sentence, execution suspended after seven and one-half years, five years of probation, and concurrent treatment with sentences in the other cases, but the record did not establish that the plea agreement included credit for time spent serving sentences in those other cases.
Procedural history
The defendant pleaded guilty under the Alford doctrine in the Superior Court and received an agreed sentence. The trial court denied his request to direct the commissioner of correction to apply specified presentence confinement credit and denied his motion to withdraw his pleas. The Appellate Court affirmed. The Supreme Court of Connecticut granted certification, reversed in part on the presentence-credit issue, and affirmed in all other respects.
Remand instructions
The judgment of the Appellate Court was reversed insofar as it upheld the trial court's conclusion that it lacked discretion to direct application of specified presentence confinement credit. The Appellate Court was directed to reverse the trial court's judgment on that issue and remand the case to the trial court to exercise its discretion in the first instance in accordance with law. The Appellate Court's judgment was affirmed in all other respects.