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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

State v. Sinchak, 229 Conn. App. 38 (2024)

Citation
State v. Sinchak, 229 Conn. App. 38 (2024)
Parent Document
State v. Sinchak, 229 Conn. App. 38 (2024)
Jurisdiction
Connecticut (state)
Effective Date
2024-11-05

Full Text

2,382 chars
imposition of sentence, argues ‘‘that the granting of a
         motion to correct a sentence imposed in an illegal man-
         ner, which upsets a prior final judgment, is a final judg-
         ment for purposes of appeal and that the state, victims,
         and/or their survivors should not be required [to] litigate
         a new sentencing proceeding many years after the fact
         before the state may appeal the granting of the motion.’’
         In support of this argument, the state relies on our
         Supreme Court’s decision in Solomon v. Keiser, 212
         Conn. 741, 562 A.2d 524 (1989), in which the court
         recognized a limited exception to the ‘‘well established
         [rule] that an order opening a judgment ordinarily is
         not a final judgment within § 52-263.’’ Id., 746. That
         exception is ‘‘where the appeal challenges the power
         of the court to act to set aside the judgment.’’ (Internal
         quotation marks omitted.) Id., 747. Our Supreme Court
         has further explained that this narrow exception applies
         only when there is a colorable claim that the trial court
         lacked jurisdiction to act altogether, as opposed to a
         claim that the court abused its discretion in acting
         within its established jurisdiction. See Wolfork v. Yale
         Medical Group, 335 Conn. 448, 463–65, 239 A.3d 272
         (2020) (distinguishing immediately appealable color-
         able claim that trial court lacked jurisdiction from claim
         of incorrect decision made in course of exercising its
         jurisdiction).
            In the present case, the state does not argue that the
         trial court lacked jurisdiction to grant the defendant’s
         motion to correct an illegal sentence. In fact, as the
         state acknowledges, Practice Book § 43-22 expressly
         authorizes the trial court to entertain such motions ‘‘at
         any time.’’ The state simply disagrees with the court’s
         conclusion that the defendant’s sentence was illegal
         and does not make any colorable claim that the court
         did not have jurisdiction to grant the defendant’s
         motion. For this reason, the state’s reliance on Solomon
         and its progeny is misplaced.
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