Alford doctrine (Connecticut) · Go Syfert
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Alford doctrine in Connecticut

264 Connecticut opinions name it 3 courts 1980–2026 41 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 (24)

CaseFollowedCited
North Carolina v. Alfordgreen
scotus · 1970 · cited in 102 Connecticut opinions naming this issue, 1980–2026
2 sentences

2026Less than ten days after the court sentenced the petitioner in this case, Gomez pleaded guilty, pursuant to the Alford doctrine,3 to one count of hindering prosecution in the third degree in violation of General Statutes (Rev. to 2009) § 53a-167, which is a class D felony that carries a sentence of up to 2 The state originally attempted to charge Gomez with accessory to murder in violation of § 53a-54a (a) and General Statutes § 53a-8, but a Superior Court judge denied the warrant application. 3 “Under North Carolina v. Alford, 400 U.S. 25 , 91 S. Ct. 160 , 27 L. Ed. 2d 162 (1970), a criminal

2026Less than ten days after the court sentenced the petitioner in this case, Gomez pleaded guilty, pursuant to the Alford doctrine,3 to one count of hindering prosecution in the third degree in violation of General Statutes (Rev. to 2009) § 53a-167, which is a class D felony that carries a sentence of up to 2 The state originally attempted to charge Gomez with accessory to murder in violation of § 53a-54a (a) and General Statutes § 53a-8, but a Superior Court judge denied the warrant application. 3 “Under North Carolina v. Alford, 400 U.S. 25 , 91 S. Ct. 160 , 27 L. Ed. 2d 162 (1970), a criminal

61102
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’’ [

520
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.

320
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

25
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.

24
State v. Fairchildgreen
connappct · 2015 · cited in 2 Connecticut opinions naming this issue, 2015–2018
22
People v. Birdsonggreen
colo · 1998 · cited in 2 Connecticut opinions naming this issue, 2002–2004
22
People v. Waltersgreen
nycountyct · 1995 · cited in 2 Connecticut opinions naming this issue, 2002–2004
22
Oppel v. Lopesgreen
conn · 1986 · cited in 2 Connecticut opinions naming this issue, 1989–1991
22
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. Ed. 2d 215 (1963) (suppression by prosecution of evidence favorable to accused upon request violates due process when evidence is material either to g

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. Ed. 2d 215 (1963) (suppression by prosecution of evidence favorable to accused upon request violates due process when evidence is material either to g

13
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. Ed. 2d 215 (1963) (suppression by prosecution of evidence favorable to accused upon request violates due process when evidence is material either to g

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. Ed. 2d 215 (1963) (suppression by prosecution of evidence favorable to accused upon request violates due process when evidence is material either to g

13
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

13
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).

13
Tyson v. Wardengreen
connappct · 1991 · cited in 3 Connecticut opinions naming this issue, 1993–2000
13
State v. Davisgreen
conn · 1994 · cited in 2 Connecticut opinions naming this issue, 2006–2019
12
Town of Groton v. United Steelworkers of Americagreen
conn · 2000 · cited in 2 Connecticut opinions naming this issue, 2004–2014
12
State v. Singletongreen
conn · 2005 · cited in 2 Connecticut opinions naming this issue, 2009–2013
12
Connecticut v. Whelangreen
scotus · 1986 · cited in 2 Connecticut opinions naming this issue, 1989–1990
12
California v. Tyberggreen
scotus · 1986 · cited in 2 Connecticut opinions naming this issue, 1989–1990
12
State v. Whelangreen
conn · 1986 · cited in 2 Connecticut opinions naming this issue, 1989–1990
12
Love v. Commissioner of Correctiongreen
connappct · 2024 · cited in 1 Connecticut opinions naming this issue, 2025–2025
11
Sokoloff v. Saxbegreen
ca2 · 1974 · cited in 1 Connecticut opinions naming this issue, 2022–2022
11
Nieves v. Commissioner of Correctiongreen
connappct · 2016 · cited in 1 Connecticut opinions naming this issue, 2022–2022
11
Leon v. Comm'r of Corr.green
conn · 2019 · cited in 1 Connecticut opinions naming this issue, 2022–2022
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (56)

CaseCitedYears
State v. Webb green
connappct · 2001
2 sentences

2024The petitioner has previously, and without success, litigated three other petitions for a writ of habeas corpus to decision after trials on the merits.5 See Cator v. Warden, Docket No. CV-XX-XXXXXXX-S, 2004 WL 503831 (Conn. Super. February 25, 2004) (Fuger, J.), appeal 3 See North Carolina v. Alford, 400 U.S. 25, 37 , 91 S. Ct. 160 , 27 L. Ed. 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 omitte

2024The petitioner has previously, and without success, litigated three other petitions for a writ of habeas corpus to decision after trials on the merits.5 See Cator v. Warden, Docket No. CV-XX-XXXXXXX-S, 2004 WL 503831 (Conn. Super. February 25, 2004) (Fuger, J.), appeal 3 See North Carolina v. Alford, 400 U.S. 25, 37 , 91 S. Ct. 160 , 27 L. Ed. 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 omitte

142001–2024
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).

112010–2018
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).

92001–2004
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).

82008–2009
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.

62007–2009
State v. Daniels red
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).

61999–2008
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.

61991–1991
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 controversy 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 controversy 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).

52009–2025
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.

52005–2025
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).

52011–2019
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

42021–2022
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). 3 Practice Book § 39-27 provides in relevant part: ‘‘The grounds for allowing the defendant to withdraw his or her plea of guilty after acceptance are as follows . . . ‘‘(2) The plea was involuntary, or it was entered without knowledge of the natu

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). 3 Practice Book § 39-27 provides in relevant part: ‘‘The grounds for allowing the defendant to withdraw his or her plea of guilty after acceptance are as follows . . . ‘‘(2) The plea was involuntary, or it was entered without knowledge of the natu

42016–2022
Strickland v. Washington green
scotus · 1984
2 sentences

2020The sole question presented by the petitioner on appeal is ‘‘[d]id the habeas court erroneously conclude that trial counsel’s failure to file a motion to dismiss the charge of home invasion did not constitute ineffective assistance under Strickland v. Washington [ 466 U.S. 668, 687 , 104 S. Ct. 2052 , 80 L. Ed. 2d 674 (1984)]?’’ The petitioner had pleaded guilty to that charge pursuant to the Alford doctrine.1 This court, however, affirmed the judgment of the habeas court, after raising, sua sponte, the issue of whether the petitioner had waived his right to raise a claim of ineffective assist

2020The sole question presented by the petitioner on appeal is ‘‘[d]id the habeas court erroneously conclude that trial counsel’s failure to file a motion to dismiss the charge of home invasion did not constitute ineffective assistance under Strickland v. Washington [ 466 U.S. 668, 687 , 104 S. Ct. 2052 , 80 L. Ed. 2d 674 (1984)]?’’ The petitioner had pleaded guilty to that charge pursuant to the Alford doctrine.1 This court, however, affirmed the judgment of the habeas court, after raising, sua sponte, the issue of whether the petitioner had waived his right to raise a claim of ineffective assist

42004–2022
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.

42016–2018
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).

41989–2000
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

32010–2021
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).

32016–2018
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.

32016–2018
Misenti v. Comm'r of Corr. 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).

32016–2018
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).

31989–2013
State v. Stevens green
connappct · 2004
2 sentences

2008Subsequently, the petitioner filed a petition for a writ of habeas corpus and, thereafter, an amended petition, claiming that (1) under State v. Stevens, 85 Conn. App. 473, 478-80 , 857 A.2d 972 (2004), 7 the trial court had violated his constitutional due process rights when it imposed, in connection with his plea agreement in the assault case, the “no arrest” condition, which included arrests that were beyond the petitioner’s control (count one), (2) he was denied effective assistance of counsel when his trial counsel failed to advise him adequately about his parole eligibility and, therefor

2008Subsequently, the petitioner filed a petition for a writ of habeas corpus and, thereafter, an amended petition, claiming that (1) under State v. Stevens, 85 Conn. App. 473, 478-80 , 857 A.2d 972 (2004), 7 the trial court had violated his constitutional due process rights when it imposed, in connection with his plea agreement in the assault case, the “no arrest” condition, which included arrests that were beyond the petitioner’s control (count one), (2) he was denied effective assistance of counsel when his trial counsel failed to advise him adequately about his parole eligibility and, therefor

32006–2008
Lawrence v. Kozlowski green
scotus · 1977
22014–2025
Lawrence v. Kozlowski green
conn · 1976
22014–2025
Brady v. Maryland green
scotus · 1963
21989–2023
Robles v. Commissioner of Correction green
connappct · 2016
22018–2022
Commissioner of Correction v. Gordon green
conn · 1994
21999–2022
Robles v. Comm'r of Corr. green
conn · 2017
22018–2022
State v. Walker green
connappct · 2019
22021–2021
State v. Walker green
conn · 2019
22021–2021
State v. Godek green
conn · 1980
22002–2019
State v. Gonzalez green
conn · 2016
22016–2018
State v. Robles green
conn · 2017
22017–2018
Ghant v. Commissioner green
conn · 2000
22002–2016
Bordallo v. United States green
scotus · 1989
21991–2013
State v. Tabone green
conn · 2006
22009–2012
State v. Preston green
conn · 2008
22009–2009
Copas v. Commissioner of Correction green
conn · 1995
22000–2009
State v. Alston green
ncctapp · 2000
22002–2004
James A. McCoy v. United States green
cadc · 1966
22003–2003
State v. Banks green
connappct · 1991
22002–2003

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 53a-54a (45) 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 (35) 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 266 (1977–2025) CT 264 (1980–2026) OH 252 (1990–2026) IA 192 (1979–2026) WA 125 (1987–2026) LA 90 (1988–2025) MO 88 (1983–2025) MN 77 (1989–2026) WI 76 (1981–2026) MD 71 (1981–2026) VA 64 (1995–2026) TN 61 (1991–2026) ID 59 (1975–2026) NC 57 (1992–2026) KY 56 (1985–2026) GA 55 (1988–2026) MS 37 (2005–2026) MT 35 (1992–2026) IL 34 (1987–2026) KS 33 (1980–2026) SC 25 (2005–2026) PA 25 (1984–2025) WV 20 (1996–2024) ND 18 (1982–2025) CA 17 (1989–2025) CO 17 (1982–2025) MA 17 (1984–2025) WY 16 (1992–2026) NM 16 (1996–2024) OR 13 (1973–2026) UT 13 (1993–2023) NV 12 (1994–2020) AZ 12 (1977–2017) FL 11 (1989–2025) OK 11 (2006–2020) TX 11 (1974–2025) RI 11 (1992–2019) SD 9 (1995–2019) DC 9 (1977–2024) VT 5 (1993–2021) IN 5 (1986–2005) AR 5 (2006–2024) NE 3 (2006–2017) AK 2 (1982–1982) NH 2 (1995–1995) VI 2 (1982–2026) NJ 2 (1994–2025)

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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