Connecticut General Statutes
Conn. Gen. Stat. § 44-3 (2026)
Rates to be posted. Penalty
✓ current as of May 2026
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Section 44-3 is repealed, effective October 1, 2002.
(1949 Rev., S. 6809; P.A. 02-89, S. 90.)
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Notes of Decisions
Cited in 81
cases (13 in the last 5 years), 1999–2026 · leading case: State v. Flanagan, 978 A.2d 64 (Conn. 2009).
State v. Flanagan, 978 A.2d 64 (Conn. 2009). “In a divided opinion, a three judge panel of the Appellate Court affirmed the judgment of the trial court, concluding that the trial court’s failure to canvass the defendant in accordance with Practice Book § 44-3 5 was not improper because the defendant *415 had not made a…”
State v. Flanagan, 890 A.2d 123 (Conn. App. Ct. 2006). “II The defendant's second claim is that the court improperly denied him due process of law and the constitutional right to represent himself by failing to canvass him pursuant to Practice Book § 44-3 [2] and applying an incorrect legal standard to his motion to proceed pro se.”
State v. Jordan, 44 A.3d 794 (Conn. 2012). “Jordan, clearly and unequivocally asserted his constitutional right to self-representation, thus triggering the trial court's responsibility to canvass him pursuant to Practice Book § 44-3. [1] The defendant appeals *801 from the Appellate Court's judgment affirming the judgment…”
State v. TRD, 942 A.2d 1000 (Conn. 2008). “On appeal, [5] the defendant claims that: (1) the trial court improperly failed to canvass the defendant adequately in accordance with Practice Book § 44-3 [6] before permitting him to proceed to trial without counsel, in violation of his constitutionally protected right to…”
State v. Collins, 10 A.3d 1005 (Conn. 2011). “III Finally, we turn to the defendant's second alternative ground for affirming the judgment of the Appellate Court, namely, that the trial court failed to conduct a canvass that complied with the sixth amendment to the United States constitution, [30] as well as Practice Book §…”
State v. D'Antonio, 877 A.2d 696 (Conn. 2005). “II ALTERNATE GROUND FOR AFFIRMANCE: WHETHER THE DEFENDANT KNOWINGLY AND INTELLIGENTLY WAIVED HIS RIGHT TO COUNSEL The defendant posits, as an alternate ground for affirming the judgment of the Appellate Court, a claim that he proceeded pro se without making a knowing and…”
State v. Porter, 819 A.2d 909 (Conn. App. Ct. 2003). “to breach the peace, to assault a peace officer and to interfere with a peace officer, and (3) the court violated his right to counsel under the sixth and fourteenth amendments to the United States constitution by failing to canvass him adequately to determine if he was making a…”
State v. Bangulescu, 832 A.2d 1187 (Conn. App. Ct. 2003). “Specifically, the defendant asserts that the court failed to comply with Practice Book § 44-3 during the canvass. 8 According to the defendant, the court (1) failed to make an inquiry into his intelligence and capacity to appreciate the consequences of his decision to represent…”
State v. Caracoglia, 895 A.2d 810 (Conn. App. Ct. 2006). ““[Practice Book § 44-3] was adopted in order to implement the right of a defendant in a criminal case to act as his own attorney .”
State v. Flanagan, 925 A.2d 385 (Conn. App. Ct. 2007). “[3] The defendant argues that the court should have canvassed him in accordance with Practice Book § 44-3 and then, on the basis of such canvass, exercised only limited discretion in ruling on his request.”
State v. Taylor, 776 A.2d 1154 (Conn. App. Ct. 2001). “II The defendant next claims that his waiver of counsel was ineffective because the court did not properly can *399 vass him pursuant to Practice Book § 44-3 to ensure that his waiver of the right to counsel was voluntary and intelligent.”
State v. T.R.D., 286 Conn. 191 (Conn. 2008). “On appeal, 5 the defendant claims that: (1) the trial court improperly failed to canvass the defendant adequately in accordance with Practice Book § 44-3 6 before *195 permitting him to proceed to trial without counsel, in violation of his constitutionally protected right to…”
— Conn. Gen. Stat. § 44-3(3) — 3 cases
State v. TRD, 942 A.2d 1000 (Conn. 2008). “On appeal, [5] the defendant claims that: (1) the trial court improperly failed to canvass the defendant adequately in accordance with Practice Book § 44-3 [6] before permitting him to proceed to trial without counsel, in violation of his constitutionally protected right to…”
State v. Flanagan, 890 A.2d 123 (Conn. App. Ct. 2006). “II The defendant's second claim is that the court improperly denied him due process of law and the constitutional right to represent himself by failing to canvass him pursuant to Practice Book § 44-3 [2] and applying an incorrect legal standard to his motion to proceed pro se.”
State v. Flanagan, 925 A.2d 385 (Conn. App. Ct. 2007). “[3] The defendant argues that the court should have canvassed him in accordance with Practice Book § 44-3 and then, on the basis of such canvass, exercised only limited discretion in ruling on his request.”
— Conn. Gen. Stat. § 44-3(4) — 1 case
State v. Flanagan, 925 A.2d 385 (Conn. App. Ct. 2007). “[3] The defendant argues that the court should have canvassed him in accordance with Practice Book § 44-3 and then, on the basis of such canvass, exercised only limited discretion in ruling on his request.”
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