Connecticut General Statutes

Conn. Gen. Stat. § 53a-32a (2026)

Violation of probation by certain sexual offenders

✓ current as of May 2026

Find cases: SyfertCases citing this section CT-CGAcga.ct.gov (official) JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

If a defendant who entered a plea of nolo contendere or a guilty plea under the Alford doctrine to a violation of subdivision (2) of section 53-21 of the general statutes in effect prior to October 1, 2000, section 53a-70b of the general statutes, revision of 1958, revised to January 1, 2019, or subdivision (2) of subsection (a) of section 53-21 or section 53a-70, 53a-70a, 53a-71, 53a-72a or 53a-72b, and was ordered to undergo sexual offender treatment as a condition of probation, becomes ineligible for such treatment because of such defendant's refusal to acknowledge that such defendant committed the act or acts charged, such defendant shall be deemed to be in violation of the conditions of such defendant's probation and be returned to court for proceedings in accordance with section 53a-32.

(P.A. 97-151, S. 2; P.A. 01-84, S. 16, 26; P.A. 19-189, S. 16.)

History: P.A. 01-84 replaced reference to “a violation of subdivision (2) of section 53-21” with “a violation of subdivision (2) of section 53-21 of the general statutes in effect prior to October 1, 2000,” included a violation of “subdivision (2) of subsection (a) of section 53-21” and made technical changes for purposes of gender neutrality, effective July 1, 2001; P.A. 19-189 replaced “53a-70b,” with “section 53a-70b of the general statutes, revision of 1958, revised to January 1, 2019, or”.

Trial court not required to notify defendant, upon entering guilty plea under Alford doctrine, that failure to acknowledge his guilt could result in violation of condition of his probation requiring sex offender treatment. 268 C. 174. Defendant had been afforded a full hearing on his violation of probation charge as required under Sec. 53a-32(a); even when defendant is acquitted of the underlying crime leading to probation revocation proceeding, probation may still be revoked. 281 C. 548.

Statute can be applied only prospectively; trial court improperly considered defendant's refusal to admit to guilt during sexual offender treatment as a violation of probation. 69 CA 421; judgment reversed, see 268 C. 174. Section does not prevent court from revoking probation for failure to satisfy probation condition of successful completion of sexual offender treatment related to a crime committed under Sec. 53a-21(a)(1) which is not enumerated in section because section's automatic nature does not deprive courts of discretion to revoke probation under other circumstances. 95 CA 686. Simply because automatic revocation proceeding established by section arguably is inapplicable to defendant convicted after trial, it does not follow that such defendant is immune from discretionary revocation sought by defendant's probation officer on the basis of defendant's discharge from sex offender treatment in accordance with the normal procedures set forth in Sec. 53a-32. 98 CA 579. Defendant, who was aware of the terms of his probation when entering his plea, violated his probation when he refused to discuss the details of his underlying offense at counseling. 112 CA 562.

(Return to Chapter
Table of Contents)

(Return to
List of Chapters)

(Return to
List of Titles)

Notes of Decisions

Cited in 10 cases, 2000–2018 · leading case: State v. Faraday.

Sort: Relevance Newest Treatment

State v. Faraday (Conn. 2004). · cites it 25× “General Statutes § 53a-32a provides: “If a defendant who entered a plea of nolo contendere or a guilty plea under the Alford doctrine to a violation of subdivision (2) of section 53-21 of the general statutes in effect prior to October 1,2000, subdivision (2) of subsection (a)…”

State v. Faraday (Conn. App. Ct. 2002). · cites it 21× “One issue involves an interpretation of the language of the conditions of probation, and the other involves a determination of whether General Statutes § 53a-32a should be applied to the facts of this case.”

State v. Tabone (Conn. 2009). · cites it 6× “[17] The defendant also claims that his sentence was unconstitutionally enlarged because, pursuant to General Statutes § 53a-32a, a failure to admit guilt during any sex offender treatment program automatically would result in a violation of probation, which in turn would expose…”

Faraday v. Comm'r of Corr. (Conn. App. Ct. 2008). · cites it 5× “On appeal, the petitioner claims that the court abused its discretion in denying certification to appeal and that it improperly rejected his claims that (1) his trial counsel, Paula Waite, provided ineffective assistance by failing to advise him adequately that despite his…”

State v. Roy D. (Conn. App. Ct. 2006). · cites it 6× “The defendant claims that General Statutes § 53a-32a, 9 which explicitly provides that a discharge from sex offender treatment for a failure to acknowledge guilt will automatically trigger a probation revocation proceeding, does not specifically refer to § 53-21 (a) (1), the…”

State of Tennessee v. Westley A. Albright (Tenn. 2018). · cites it 2× “2d at 587 (construing Conn. Gen. Stat. Ann. § 53a-32a).11 The Florida intermediate appellate court decision relied upon by the Gillman court subsequently was overruled by the Florida Supreme Court.”

State v. Reilly (Conn. App. Ct. 2000). · cites it 2× “General Statutes § 53a-32a. General Statutes § 53a-30 (b) specifically allows the office of adult probation to require the defendant to comply with any conditions a court could have imposed so long as this condition is not inconsistent with any condition actually imposed by the…”

State v. Misenti (Conn. App. Ct. 2009). · cites it 3× “With reference to whether the evidence established a violation of probation, General Statutes § 53a-32a provides in relevant part: “If a defendant who entered aplea of nolo contendere or a guilty plea under the [doctrine of North Carolina v.”

Andrew Burrell v. United States (2d Cir. 2004). “See Conn. Gen.Stat. § 53a-32a. The Connecticut Supreme Court recently clarified that revocation of probation in such circumstances is not “inconsistent with [a] guilty plea under the Alford doctrine.”

State v. BRUCE T. (Conn. App. Ct. 2006). · cites it 20× “On January 5, 2005, the court found that the defendant had violated the condition of his probation to undergo and successfully to complete sex offender treatment by steadfastly refusing to acknowledge his responsibility for the underlying offenses. The court then revoked the…”

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.