Alford doctrine in Connecticut

262 Connecticut opinions name it 3 courts 1980–2026 39 in the last five years

The cases below were cited by Connecticut courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (21)

Case	Followed	Cited
North Carolina v. Alfordgreen scotus · 1970 · cited in 93 Connecticut opinions naming this issue, 1980–2026 2 sentences 2025The respondent father’s trial brief, on the other hand, asserted that the guilty plea he entered into criminal court on the risk of injury charges based on Noah’s injuries was pursuant to the so-called Alford doctrine that permits a criminal defen- dant to plead guilty without admitting actual guilt.3 3 See North Carolina v. Alford, 400 U.S. 25 , 91 S. Ct. 160 , 27 L. 2025The respondent father’s trial brief, on the other hand, asserted that the guilty plea he entered into criminal court on the risk of injury charges based on Noah’s injuries was pursuant to the so-called Alford doctrine that permits a criminal defen- dant to plead guilty without admitting actual guilt.3 3 See North Carolina v. Alford, 400 U.S. 25 , 91 S. Ct. 160 , 27 L.	60	93
State v. Palmergreen conn · 1985 · cited in 20 Connecticut opinions naming this issue, 1985–2025 2 sentences 2019See State v. Palmer, 196 Conn. 157 , 169 n.3, 491 A.2d 1075 (1985) (‘‘[a] guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless’’); State v. Godek, 182 Conn. 353, 364 , 438 A.2d 114 (1980) (‘‘[t]hroughout its history . . . the plea of nolo contendere has been viewed not as an express admission of guilt but as a consent by the defendant that he may be punished as if he were guilty and a prayer for leniency’’ [ 2019See State v. Palmer, 196 Conn. 157 , 169 n.3, 491 A.2d 1075 (1985) (‘‘[a] guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless’’); State v. Godek, 182 Conn. 353, 364 , 438 A.2d 114 (1980) (‘‘[t]hroughout its history . . . the plea of nolo contendere has been viewed not as an express admission of guilt but as a consent by the defendant that he may be punished as if he were guilty and a prayer for leniency’’ [	5	20
State v. Faradaygreen conn · 2004 · cited in 20 Connecticut opinions naming this issue, 2005–2025 2 sentences 2024The entry of a guilty plea under the Alford doctrine carries the same consequences as a standard plea of guilty.’’ (Citation omitted; emphasis in original; footnote omitted; internal quotation marks omitted.) State v. Faraday, 268 Conn. 174 , 204–205, 842 A.2d 567 (2004). 4 The habeas trial transcript contains multiple spelling variations of Romowi’s last name. 2024The entry of a guilty plea under the Alford doctrine carries the same consequences as a standard plea of guilty.’’ (Citation omitted; emphasis in original; footnote omitted; internal quotation marks omitted.) State v. Faraday, 268 Conn. 174 , 204–205, 842 A.2d 567 (2004). 4 The habeas trial transcript contains multiple spelling variations of Romowi’s last name.	3	20
State v. Garvingreen conn · 1997 · cited in 5 Connecticut opinions naming this issue, 2002–2008 2 sentences 2008Thereafter, the petitioner pleaded guilty to the assault charge under the Alford doctrine. 3 At the plea hearing, the trial court, Iannotti, J., granted the petitioner’s request to postpone sentencing and to permit the petitioner to remain free on bond pending sentencing subject to certain conditions, which were imposed pursuant to State v. Garvin, 242 Conn. 296, 299-302 , 699 A.2d 921 (1997). 4 Specifically, the court advised the petitioner that, if he failed to appear at sentencing or was arrested between the date of the plea hearing and sentencing, the court would be free to sentence him to 2008Thereafter, the petitioner pleaded guilty to the assault charge under the Alford doctrine. 3 At the plea hearing, the trial court, Iannotti, J., granted the petitioner’s request to postpone sentencing and to permit the petitioner to remain free on bond pending sentencing subject to certain conditions, which were imposed pursuant to State v. Garvin, 242 Conn. 296, 299-302 , 699 A.2d 921 (1997). 4 Specifically, the court advised the petitioner that, if he failed to appear at sentencing or was arrested between the date of the plea hearing and sentencing, the court would be free to sentence him to	2	5
Baillargeon v. Commissioner of Correctiongreen connappct · 2002 · cited in 4 Connecticut opinions naming this issue, 2012–2025 2 sentences 2016This rule was 760 applied in the context of an Alford plea in Ghant v. Commissioner of Correction , 255 Conn. 1 , 14-15, 761 A.2d 740 (2000) ; see also Baillargeon v. Commissioner of Correction , 67 Conn.App. 716 , 730, 789 A.2d 1046 (2002) (our procedural rules do not require factual basis for court to accept Alford plea). 9 Put another way, a factual basis is but one way of satisfying the requirement that a plea be knowing and voluntary. 2016This rule was 760 applied in the context of an Alford plea in Ghant v. Commissioner of Correction , 255 Conn. 1 , 14-15, 761 A.2d 740 (2000) ; see also Baillargeon v. Commissioner of Correction , 67 Conn.App. 716 , 730, 789 A.2d 1046 (2002) (our procedural rules do not require factual basis for court to accept Alford plea). 9 Put another way, a factual basis is but one way of satisfying the requirement that a plea be knowing and voluntary.	2	4
People v. Waltersgreen nycountyct · 1995 · cited in 2 Connecticut opinions naming this issue, 2002–2004	2	2
People v. Birdsonggreen colo · 1998 · cited in 2 Connecticut opinions naming this issue, 2002–2004	2	2
Oppel v. Lopesgreen conn · 1986 · cited in 2 Connecticut opinions naming this issue, 1989–1991	2	2
State v. Wheatlandgreen connappct · 2006 · cited in 3 Connecticut opinions naming this issue, 2006–2023 2 sentences 2023A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’ (Emphasis omitted.) State v. Wheatland, 93 Conn. App. 232 , 234 n.1, 888 A.2d 1098 , cert. denied, 277 Conn. 919 , 895 A.2d 793 (2006).’’ 3 See Brady v. Maryland, 373 U.S. 83, 87 , 83 S. Ct. 1194 , 10 L. 2023A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’ (Emphasis omitted.) State v. Wheatland, 93 Conn. App. 232 , 234 n.1, 888 A.2d 1098 , cert. denied, 277 Conn. 919 , 895 A.2d 793 (2006).’’ 3 See Brady v. Maryland, 373 U.S. 83, 87 , 83 S. Ct. 1194 , 10 L.	1	3
Bove v. Bovegreen conn · 2006 · cited in 3 Connecticut opinions naming this issue, 2006–2023 2 sentences 2023A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’ (Emphasis omitted.) State v. Wheatland, 93 Conn. App. 232 , 234 n.1, 888 A.2d 1098 , cert. denied, 277 Conn. 919 , 895 A.2d 793 (2006).’’ 3 See Brady v. Maryland, 373 U.S. 83, 87 , 83 S. Ct. 1194 , 10 L. 2023A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’ (Emphasis omitted.) State v. Wheatland, 93 Conn. App. 232 , 234 n.1, 888 A.2d 1098 , cert. denied, 277 Conn. 919 , 895 A.2d 793 (2006).’’ 3 See Brady v. Maryland, 373 U.S. 83, 87 , 83 S. Ct. 1194 , 10 L.	1	3
State v. Wheatlandgreen conn · 2006 · cited in 3 Connecticut opinions naming this issue, 2006–2023 2 sentences 2023A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’ (Emphasis omitted.) State v. Wheatland, 93 Conn. App. 232 , 234 n.1, 888 A.2d 1098 , cert. denied, 277 Conn. 919 , 895 A.2d 793 (2006).’’ 3 See Brady v. Maryland, 373 U.S. 83, 87 , 83 S. Ct. 1194 , 10 L. 2023A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’ (Emphasis omitted.) State v. Wheatland, 93 Conn. App. 232 , 234 n.1, 888 A.2d 1098 , cert. denied, 277 Conn. 919 , 895 A.2d 793 (2006).’’ 3 See Brady v. Maryland, 373 U.S. 83, 87 , 83 S. Ct. 1194 , 10 L.	1	3
State v. Simmsgreen conn · 1989 · cited in 3 Connecticut opinions naming this issue, 1990–2020 2 sentences 2020A defendant who pleads guilty under the Alford doctrine does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea.’’ (Internal quotation marks omitted.) Diaz v. Commissioner of Correction, supra, 185 Conn. App. 687 n.1 ; accord State v. Simms, 211 Conn. 1 , 3–4, 557 A.2d 914 (1989). 3 In his brief to this court, the respondent contends that he did not waive or otherwise abandon a claim that the petitioner had waived his claim of ineffective assistance because, in his return, which the respondent filed in re 2020A defendant who pleads guilty under the Alford doctrine does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea.’’ (Internal quotation marks omitted.) Diaz v. Commissioner of Correction, supra, 185 Conn. App. 687 n.1 ; accord State v. Simms, 211 Conn. 1 , 3–4, 557 A.2d 914 (1989). 3 In his brief to this court, the respondent contends that he did not waive or otherwise abandon a claim that the petitioner had waived his claim of ineffective assistance because, in his return, which the respondent filed in re	1	3
State v. Niblackgreen conn · 1991 · cited in 3 Connecticut opinions naming this issue, 1994–2015 2 sentences 2015State v. Niblack, 220 Conn. 270, 277 , 596 A.2d 407 (1991) (holding that petitioner was barred from ‘‘the later assertion of a constitutional challenge to a pretrial proceeding’’ because his Alford plea constituted waiver of defects antecedent to entry of plea); State v. Madera, 198 Conn. 92, 97 , 503 A.2d 136 (1985). 2015State v. Niblack, 220 Conn. 270, 277 , 596 A.2d 407 (1991) (holding that petitioner was barred from ‘‘the later assertion of a constitutional challenge to a pretrial proceeding’’ because his Alford plea constituted waiver of defects antecedent to entry of plea); State v. Madera, 198 Conn. 92, 97 , 503 A.2d 136 (1985).	1	3
Tyson v. Wardengreen connappct · 1991 · cited in 3 Connecticut opinions naming this issue, 1993–2000	1	3
State v. Davisgreen conn · 1994 · cited in 2 Connecticut opinions naming this issue, 2006–2019	1	2
Town of Groton v. United Steelworkers of Americagreen conn · 2000 · cited in 2 Connecticut opinions naming this issue, 2004–2014	1	2
State v. Singletongreen conn · 2005 · cited in 2 Connecticut opinions naming this issue, 2009–2013	1	2
State v. Whelangreen conn · 1986 · cited in 2 Connecticut opinions naming this issue, 1989–1990	1	2
Bowen v. Peoplesgreen scotus · 1986 · cited in 2 Connecticut opinions naming this issue, 1989–1990	1	2
Washington v. United Statesgreen scotus · 1986 · cited in 2 Connecticut opinions naming this issue, 1989–1990	1	2
California v. Tyberggreen scotus · 1986 · cited in 2 Connecticut opinions naming this issue, 1989–1990	1	2

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway.

Also cited on this issue (59)

Case	Cited	Years
State v. Webb green connappct · 2001 2 sentences 2024Ed. 2d 162 (1970). ‘‘A defendant who pleads guilty under the Alford doctrine does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea.’’ (Internal quotation marks omitted.) State v. Webb, 62 Conn. App. 805 , 807 n.1, 772 A.2d 690 (2001). 4 Johnson had been charged with murder in violation of § 53a-54a (a), kidnapping in the second degree in violation of § 53a-94 (a), felony murder in violation of § 53a-54c, capital felony in violation of General Statutes (Rev. to 1995) § 53a-54b (5) and conspiracy to commi 2024Ed. 2d 162 (1970). ‘‘A defendant who pleads guilty under the Alford doctrine does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea.’’ (Internal quotation marks omitted.) State v. Webb, 62 Conn. App. 805 , 807 n.1, 772 A.2d 690 (2001). 4 Johnson had been charged with murder in violation of § 53a-54a (a), kidnapping in the second degree in violation of § 53a-94 (a), felony murder in violation of § 53a-54c, capital felony in violation of General Statutes (Rev. to 1995) § 53a-54b (5) and conspiracy to commi	14	2001–2024
Johnson v. Commissioner of Correction green conn · 2008 2 sentences 2018A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state's evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless." (Internal quotation marks omitted.) Johnson v. Commissioner of Correction , 285 Conn. 556 , 558 n.2, 941 A.2d 248 (2008). 2018A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state's evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless." (Internal quotation marks omitted.) Johnson v. Commissioner of Correction , 285 Conn. 556 , 558 n.2, 941 A.2d 248 (2008).	11	2010–2018
Henry v. Commissioner of Correction green connappct · 2000 2 sentences 2002“A defendant who pleads guilty under the Alford doctrine does not admit guilt, but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea.” Henry v. Commissioner of Correction, 60 Conn. App. 313 , 315 n.1, 759 A.2d 118 (2000). 2002“A defendant who pleads guilty under the Alford doctrine does not admit guilt, but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea.” Henry v. Commissioner of Correction, 60 Conn. App. 313 , 315 n.1, 759 A.2d 118 (2000).	9	2001–2004
State v. Fowlkes green conn · 2007 2 sentences 2009A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a gmlty plea nevertheless.” (Internal quotation marks omitted.) State v. Fowlkes, 283 Conn. 735 , 736 n.1, 930 A.2d 644 (2007). 2009A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a gmlty plea nevertheless.” (Internal quotation marks omitted.) State v. Fowlkes, 283 Conn. 735 , 736 n.1, 930 A.2d 644 (2007).	8	2008–2009
State v. Stevens green conn · 2006 2 sentences 2009A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.” (Internal quotation marks omitted.) State v. Stevens, 278 Conn. 1 , 3 n.2, 895 A.2d 771 (2006). 2 In accordance with our policy of protecting the privacy interests of the victims of sexual assault, we decline to identify the victim or others through whom the victim’s identity may be ascertained. 2009A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.” (Internal quotation marks omitted.) State v. Stevens, 278 Conn. 1 , 3 n.2, 895 A.2d 771 (2006). 2 In accordance with our policy of protecting the privacy interests of the victims of sexual assault, we decline to identify the victim or others through whom the victim’s identity may be ascertained.	6	2007–2009
State v. Daniels green conn · 1999 2 sentences 2005A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.” (Citation omitted; internal quotation marks omitted.) State v. Daniels, 248 Conn. 64, 66-67 n.2, 726 A.2d 520 (1999). 2005A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.” (Citation omitted; internal quotation marks omitted.) State v. Daniels, 248 Conn. 64, 66-67 n.2, 726 A.2d 520 (1999).	6	1999–2008
State v. Wright green conn · 1988 2 sentences 1991The Petitioner also relies on State v. Wright, 207 Conn. 276 , 542 A.2d 299 (1988), in arguing that the court reviewed a challenge to the racial composition of a grand jury on appeal despite the fact that the appellant had pleaded guilty under the Alford doctrine to both parts of the indictment. 1991The Petitioner also relies on State v. Wright, 207 Conn. 276 , 542 A.2d 299 (1988), in arguing that the court reviewed a challenge to the racial composition of a grand jury on appeal despite the fact that the appellant had pleaded guilty under the Alford doctrine to both parts of the indictment.	6	1991–1991
State v. Boscarino green connappct · 2004 2 sentences 2025In pleading guilty, however, the defendant acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea.’’ (Internal quotation marks omitted.) State v. Boscarino, 86 Conn. App. 447 , 451 n.4, 861 A.2d 579 (2004). ‘‘United States Supreme Court cases have described Alford pleas as permitting a defendant to plead guilty while protesting innocence. 2025In pleading guilty, however, the defendant acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea.’’ (Internal quotation marks omitted.) State v. Boscarino, 86 Conn. App. 447 , 451 n.4, 861 A.2d 579 (2004). ‘‘United States Supreme Court cases have described Alford pleas as permitting a defendant to plead guilty while protesting innocence.	5	2005–2025
State v. TD green conn · 2008 2 sentences 2025Faraday is one of a series of cases holding that an Alford guilty plea may be used, in subsequent proceedings for violation of probation, to establish ‘‘that a conviction following a jury verdict is indistinguishable from a conviction following a guilty plea or Alford plea for purposes of eliminating any contro- versy over whether the criminal conduct underlying a violation of probation has occurred.’’ State v. T.D., 286 Conn. 353, 366 , 944 A.2d 288 (2008). 2025Faraday is one of a series of cases holding that an Alford guilty plea may be used, in subsequent proceedings for violation of probation, to establish ‘‘that a conviction following a jury verdict is indistinguishable from a conviction following a guilty plea or Alford plea for purposes of eliminating any contro- versy over whether the criminal conduct underlying a violation of probation has occurred.’’ State v. T.D., 286 Conn. 353, 366 , 944 A.2d 288 (2008).	5	2009–2025
State v. Pentland green conn · 2010 2 sentences 2019A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state's evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless." (Internal quotation marks omitted.) State v. Pentland , 296 Conn. 305 , 308 n.3, 994 A.2d 147 (2010). 2019A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state's evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless." (Internal quotation marks omitted.) State v. Pentland , 296 Conn. 305 , 308 n.3, 994 A.2d 147 (2010).	5	2011–2019
State v. Simpson green conn · 2018 2 sentences 2022By entering such a plea, a defendant may be able to avoid formally admitting guilt at the time of sentencing, but he nonetheless consents to being treated as if he were guilty with no assurances to the contrary.’’ (Emphasis omitted; internal quotation marks omitted.) State v. Simpson, 329 Conn. 820 , 824 n.4, 189 A.3d 1215 (2018). 9 Around the same time that this guilty plea was entered, in a separate criminal case, the petitioner also pleaded guilty under the Alford doctrine to possession of narcotics in violation of General Statutes (Supp. 2014) § 21a-279 (a), arising from an incident in Man 2022By entering such a plea, a defendant may be able to avoid formally admitting guilt at the time of sentencing, but he nonetheless consents to being treated as if he were guilty with no assurances to the contrary.’’ (Emphasis omitted; internal quotation marks omitted.) State v. Simpson, 329 Conn. 820 , 824 n.4, 189 A.3d 1215 (2018). 9 Around the same time that this guilty plea was entered, in a separate criminal case, the petitioner also pleaded guilty under the Alford doctrine to possession of narcotics in violation of General Statutes (Supp. 2014) § 21a-279 (a), arising from an incident in Man	4	2021–2022
State v. Celaj neutral connappct · 2016 2 sentences 2022A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’’ (Internal quotation marks omitted.) State v. Celaj, 163 Conn. App. 716 , 718–19 n.3, 141 A.3d 870 (2016). 2 Public Act 18-63 provides in relevant part: ‘‘Be it enacted by the Senate and House of Representatives in General Assembly convened: ‘‘Section 1. 2022A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’’ (Internal quotation marks omitted.) State v. Celaj, 163 Conn. App. 716 , 718–19 n.3, 141 A.3d 870 (2016). 2 Public Act 18-63 provides in relevant part: ‘‘Be it enacted by the Senate and House of Representatives in General Assembly convened: ‘‘Section 1.	4	2016–2022
Rodriguez v. Commissioner of Correction neutral connappct · 2016 2 sentences 2018A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state's evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless." (Internal quotation marks omitted.) Rodriguez v. Commissioner of Correction , 167 Conn. App. 233 , 234 n.1, 143 A.3d 630 , cert. denied, 323 Conn. 929 , 150 A.3d 231 (2016). 3 The petitioner later was charged with violation of a protective order when the victim's mother brought the victim to see him during the pendency of the criminal case. 2018A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state's evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless." (Internal quotation marks omitted.) Rodriguez v. Commissioner of Correction , 167 Conn. App. 233 , 234 n.1, 143 A.3d 630 , cert. denied, 323 Conn. 929 , 150 A.3d 231 (2016). 3 The petitioner later was charged with violation of a protective order when the victim's mother brought the victim to see him during the pendency of the criminal case.	4	2016–2018
State v. James green conn · 1985 2 sentences 2000State v. James, 197 Conn. 358 , 359 n.l, 497 A.2d 402 (1985); State v. Palmer, 196 Conn. 157 , 169 n.3, 491 A.2d 1075 (1985). 2000State v. James, 197 Conn. 358 , 359 n.l, 497 A.2d 402 (1985); State v. Palmer, 196 Conn. 157 , 169 n.3, 491 A.2d 1075 (1985).	4	1989–2000
Strickland v. Washington green scotus · 1984 2 sentences 2022See Nieves v. Commis- sioner of Correction, 169 Conn. App. 587, 597 , 152 A.3d 570 (2016), cert. denied, 324 Conn. 915 , 153 A.3d 1288 (2017); id., 597 n.13 (well settled that reviewing court can find against petitioner on either ground of Strickland v. Washington, 466 U.S. 668, 687 , 104 S. Ct. 2052 , 80 L. 2022See Nieves v. Commis- sioner of Correction, 169 Conn. App. 587, 597 , 152 A.3d 570 (2016), cert. denied, 324 Conn. 915 , 153 A.3d 1288 (2017); id., 597 n.13 (well settled that reviewing court can find against petitioner on either ground of Strickland v. Washington, 466 U.S. 668, 687 , 104 S. Ct. 2052 , 80 L.	3	2004–2022
State v. Tabone green conn · 2009 2 sentences 2021A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’’ (Internal quotation marks omitted.) State v. Tabone, 292 Conn. 417 , 421 n.7, 973 A.2d 74 (2009). 3 Practice Book § 43-22 provides: ‘‘The judicial authority may at any time correct an illegal sentence or other illegal disposition, or it may correct a sentence imposed in an illegal manner or any other disposition made in an illegal manner.’’ 4 General 2021A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’’ (Internal quotation marks omitted.) State v. Tabone, 292 Conn. 417 , 421 n.7, 973 A.2d 74 (2009). 3 Practice Book § 43-22 provides: ‘‘The judicial authority may at any time correct an illegal sentence or other illegal disposition, or it may correct a sentence imposed in an illegal manner or any other disposition made in an illegal manner.’’ 4 General	3	2010–2021
H-K Props., LLC v. Town of Mansfield Planning & Zoning Comm'n neutral conn · 2016 2 sentences 2016A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state's evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless." (Internal quotation marks omitted.) Rodriguez v. Commissioner of Correction , 167 Conn.App. 233 , 234 n.1, 143 A.3d 630 (2016) ; Misenti v. Commissioner of Correction , 165 Conn.App. 548 , 551-52 n.2, 140 A.3d 222 , cert. denied, 322 Conn. 902 , 138 A.3d 932 (2016). 2016A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state's evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless." (Internal quotation marks omitted.) Rodriguez v. Commissioner of Correction , 167 Conn.App. 233 , 234 n.1, 143 A.3d 630 (2016) ; Misenti v. Commissioner of Correction , 165 Conn.App. 548 , 551-52 n.2, 140 A.3d 222 , cert. denied, 322 Conn. 902 , 138 A.3d 932 (2016).	3	2016–2018
State v. Robles green connappct · 2016 2 sentences 2017A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’’ (Internal quotation marks omitted.) State v. Robles, 169 Conn. App. 127 , 128 n.1, 150 A.3d 687 (2016), cert. denied, 324 Conn. 906 , A.3d (2017). 3 The petitioner had brought a $1000 check from a local business as part of the $3000. 2017A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state’s evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless.’’ (Internal quotation marks omitted.) State v. Robles, 169 Conn. App. 127 , 128 n.1, 150 A.3d 687 (2016), cert. denied, 324 Conn. 906 , A.3d (2017). 3 The petitioner had brought a $1000 check from a local business as part of the $3000.	3	2016–2018
Misenti v. Commissioner of Correction neutral connappct · 2016 2 sentences 2016A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state's evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless." (Internal quotation marks omitted.) Rodriguez v. Commissioner of Correction , 167 Conn.App. 233 , 234 n.1, 143 A.3d 630 (2016) ; Misenti v. Commissioner of Correction , 165 Conn.App. 548 , 551-52 n.2, 140 A.3d 222 , cert. denied, 322 Conn. 902 , 138 A.3d 932 (2016). 2016A guilty plea under the Alford doctrine is a judicial oxymoron in that the defendant does not admit guilt but acknowledges that the state's evidence against him is so strong that he is prepared to accept the entry of a guilty plea nevertheless." (Internal quotation marks omitted.) Rodriguez v. Commissioner of Correction , 167 Conn.App. 233 , 234 n.1, 143 A.3d 630 (2016) ; Misenti v. Commissioner of Correction , 165 Conn.App. 548 , 551-52 n.2, 140 A.3d 222 , cert. denied, 322 Conn. 902 , 138 A.3d 932 (2016).	3	2016–2018
State v. Rish green connappct · 1989 2 sentences 1989This court recently held in State v. Rish, 17 Conn. App. 447, 451-52 , 553 A.2d 1145 (1989), that the failure of the trial court to inform the defendant of the precise amount of the fine that could have been imposed as a result of his Alford plea did not constitute defective compliance with Practice Book § 711 (4). 1989This court recently held in State v. Rish, 17 Conn. App. 447, 451-52 , 553 A.2d 1145 (1989), that the failure of the trial court to inform the defendant of the precise amount of the fine that could have been imposed as a result of his Alford plea did not constitute defective compliance with Practice Book § 711 (4).	3	1989–2013
State v. Stevens green connappct · 2004	3	2006–2008
Lawrence v. Kozlowski green conn · 1976	2	2014–2025
Lawrence v. Kozlowski green scotus · 1977	2	2014–2025
Allen v. United States green scotus · 1977	2	2014–2025
Brady v. Maryland green scotus · 1963	2	1989–2023
Commissioner of Correction v. Gordon green conn · 1994	2	1999–2022
Robles v. Comm'r of Corr. green conn · 2017	2	2018–2022
Robles v. Commissioner of Correction green connappct · 2016	2	2018–2022
State v. Walker green conn · 2019	2	2021–2021
McClain v. Comm'r of Corr. green conn · 2019	2	2021–2021
State v. Walker green connappct · 2019	2	2021–2021
State v. Godek green conn · 1980	2	2002–2019
Elbert v. Board of Education green scotus · 1981	2	2002–2019
State v. Gonzalez green conn · 2016	2	2016–2018
Straw Pond Assocs., LLC v. Fitzpatrick, Mariano & Santos, P.C. green conn · 2016	2	2016–2018
State v. Robles green conn · 2017	2	2017–2018
Ghant v. Commissioner green conn · 2000	2	2002–2016
State v. Briggs green conn · 1989	2	1991–2013
State v. Rish green conn · 1989	2	1991–2013
Austin Products Co. v. Workers' Compensation Insurers Rating Association of Minnesota green scotus · 1989	2	1991–2013

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 53a-54a (44) CT § Conn. Gen. Stat. § 53a-70 (41) CT § Conn. Gen. Stat. § 53-21 (40) CT § Conn. Gen. Stat. § 53a-134 (38) CT § Conn. Gen. Stat. § 53a-32 (34) CT § Conn. Gen. Stat. § 53a-59 (29) CT § Conn. Gen. Stat. § 53a-48 (25) CT § Conn. Gen. Stat. § 53a-49 (24) CT § Conn. Gen. Stat. § 43-22 (23) CT § Conn. Gen. Stat. § 51-199 (19) CT § Conn. Gen. Stat. § 54-86e (19) CT § Conn. Gen. Stat. § 29-35 (18)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 265 (1977–2025) CT 262 (1980–2026) OH 241 (1990–2026) IA 182 (1979–2026) WA 123 (1987–2026) LA 90 (1988–2025) MO 87 (1983–2025) MN 75 (1989–2026) WI 75 (1981–2026) MD 67 (1981–2026) VA 61 (1995–2025) ID 59 (1975–2026) TN 56 (1991–2026) GA 53 (1988–2026) KY 53 (1985–2026) NC 51 (1992–2026) MS 36 (2005–2024) MT 35 (1992–2026) IL 33 (1987–2026) KS 32 (1980–2026) PA 25 (1984–2025) SC 23 (2005–2024) WV 20 (1996–2024) ND 18 (1982–2025) CO 18 (1982–2025) MA 17 (1984–2025) CA 17 (1989–2025) NM 16 (1996–2024) WY 15 (1992–2026) OR 14 (1973–2026) UT 13 (1993–2023) AZ 12 (1977–2017) NV 12 (1994–2020) OK 11 (2006–2020) FL 11 (1989–2025) RI 11 (1992–2019) TX 10 (1974–2025) DC 9 (1977–2024) SD 9 (1995–2019) IN 5 (1986–2005) AR 5 (2006–2024) VT 5 (1993–2021) NE 3 (2006–2024) NJ 2 (1994–2025) VI 2 (1982–2026) NH 2 (1995–1995) AK 2 (1982–1982)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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