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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

State v. Sinchak, 205 Conn. App. 346 (2021)

Citation
State v. Sinchak, 205 Conn. App. 346 (2021)
Parent Document
State v. Sinchak, 205 Conn. App. 346 (2021)
Jurisdiction
Connecticut (state)
Effective Date
2021-06-22

Full Text

3,304 chars
The defendant, who had been convicted of murder and two counts of kidnap-
   ping in the first degree, appealed to this court from the judgment of the
   trial court denying his motion to correct an illegal sentence. The judge
   who presided over the defendant’s probable cause hearing offered the
   defendant a plea deal at a pretrial conference, proposing a thirty year
   term of imprisonment if the defendant agreed to plead guilty to murder.
   The defendant rejected the deal and it was withdrawn. A jury found the
   defendant guilty of all charges and, at his sentencing hearing, the judge
   who had presided over the trial imposed a sentence of sixty years of
   imprisonment on the murder count and eighteen years on each of the
   kidnapping counts, to run consecutively, for a total effective sentence
   of ninety-six years of imprisonment. The defendant filed an application
   with the sentence review division of the Superior Court, requesting a
   reduction of his sentence, which he claimed was excessive. His request
   was denied and the sentence was upheld. The defendant then filed a
   motion to correct an illegal sentence, claiming that, by imposing a sen-
   tence substantially longer than that which was proposed pretrial, the
   sentencing judge was punishing the defendant for rejecting the plea
   deal and, in doing so, violated the defendant’s constitutional right to
   due process. Following a hearing, the trial court denied the defendant’s
   motion and the defendant appealed to this court. Held that the trial court
   properly denied the defendant’s motion to correct an illegal sentence
   because the record did not contain any indication of vindictiveness on
   behalf of the sentencing judge: the fact that the length of the sentence
   imposed greatly exceeded the length of the sentence proposed prior to
   trial did not give rise to an inference of vindictiveness when the record
   was considered as a whole, including the defendant’s background, his
   long and violent criminal history, and evidence that the defendant posed
   such a grave danger to the community that he should spend the remain-
   der of his life in prison; moreover, there were legitimate bases for
   the disparity between the sentence proposed pretrial and the sentence
   imposed posttrial, including that the trial provided the sentencing judge
   with the opportunity to gain a greater appreciation of the evidence and
   of the effect of the defendant’s actions on his victims and their families,
   that a guilty plea would have shown evidence of the defendant’s willing-
   ness to accept responsibility for his crimes, which is a mitigating factor
   for sentencing, whereas his refusal to accept responsibility even after
   his trial demonstrated a lack of remorse and dim prospects for rehabilita-
   tion, and that the sentences were considered by two different judges,
   with different sentencing philosophies and priorities, at different stages
   of the case; furthermore, the sentencing judge was not required to
   expressly disavow a vindictive or retaliatory motive for the sentencing
   because the facts of the case did not give rise to a presumption of
   vindictiveness.
        Argued October 6, 2020—officially released June 22, 2021 Procedural History