Howard v. Commissioner of Correction

236 Conn. App. 506
CourtConnecticut Appellate Court
DecidedNovember 25, 2025
DocketAC47404
StatusPublished

This text of 236 Conn. App. 506 (Howard v. Commissioner of Correction) is published on Counsel Stack Legal Research, covering Connecticut Appellate Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Howard v. Commissioner of Correction, 236 Conn. App. 506 (Colo. Ct. App. 2025).

Opinion

************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopin- ion motions and petitions for certification is the “offi- cially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Jour- nal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************ Page 0 CONNECTICUT LAW JOURNAL 0, 0

2 ,0 0 Conn. App. 1 Howard v. Commissioner of Correction

ASHLEY HOWARD v. COMMISSIONER OF CORRECTION (AC 47404) Cradle, C. J., and Alvord and Wilson, Js.

Syllabus

The petitioner, who previously had been convicted of murder, on a plea of guilty pursuant to North Carolina v. Alford (400 U.S. 25), and, in a separate docket, had admitted to a violation of probation (collectively, plea), appealed following the granting of her petition for certification to appeal from the habeas court’s judgment denying in part and dismissing in part her petition for a writ of habeas corpus. She claimed, inter alia, that the court improperly dismissed her claim that her plea was involuntary. Held:

The habeas court properly denied the petitioner’s claim that she was deprived of the effective assistance of trial counsel during the plea process, as she failed to demonstrate that, but for the alleged deficient performance of her trial counsel, she would have proceeded to trial and, therefore, that she was prejudiced by trial counsel’s performance.

The habeas court properly dismissed the petitioner’s claim that her plea was involuntary, as the petitioner failed to raise the issue before the trial court or on direct appeal, and the petitioner failed to show either good cause or actual prejudice sufficient to excuse the procedural default.

Argued May 19—officially released November 25, 2025

Procedural History

Amended petition for a writ of habeas corpus, brought to the Superior Court in the judicial district of Tolland and tried to the court, Bhatt, J.; judgment denying in part and dismissing in part the petition, from which the petitioner, on the granting of certification, appealed to this court. Affirmed.

Judie Marshall, assigned counsel, for the appellant (petitioner). Rebecca Z. Oestreicher, special deputy assistant state’s attorney, with whom, on the brief, were Matthew 0, 0 CONNECTICUT LAW JOURNAL Page 1

0 Conn. App. 1 ,0 3 Howard v. Commissioner of Correction

Gedansky, state’s attorney, and Erin Stack, assistant state’s attorney, for the appellee (respondent).

Opinion

WILSON, J. Following the granting of her petition for certification to appeal, the petitioner, Ashley Howard, appeals from the judgment of the habeas court, Bhatt, J., denying in part and dismissing in part her petition for a writ of habeas corpus. The petitioner claims that the habeas court improperly (1) denied her claim that she was denied the effective assistance of trial counsel and (2) dismissed her claim that her guilty plea was involuntary. We disagree and, accordingly, affirm the judgment of the habeas court. The following facts, which were either found by the habeas court or are not in dispute, and procedural his- tory are relevant to our resolution of the petitioner’s appeal. In the proceedings before the trial court in con- nection with the petitioner’s criminal charges, the peti- tioner was represented by Attorney Richard Cohen. On June 18, 2013, the petitioner pleaded guilty pursuant to the Alford doctrine1 to one count of murder in violation of General Statutes § 53a-54a and, under a separate criminal docket, admitted to a violation of probation in violation of General Statutes § 53a-32 (collectively, plea). The petitioner’s murder conviction stems from an early morning dispute on June 9, 2012, between the petitioner and the victim regarding the victim’s alleged infringement on the drug selling territory of the peti- tioner and her codefendant. During the dispute, the petitioner approached the victim as he stood on a Hart- ford sidewalk, discharged a firearm at close range, and killed the victim with a single gunshot to the head. Following a canvass, the court, Alexander, J., accepted 1 See North Carolina v. Alford, 400 U.S. 25, 37, 91 S. Ct. 160, 27 L. Ed. 2d 162 (1970). Page 2 CONNECTICUT LAW JOURNAL 0, 0

4 ,0 0 Conn. App. 1 Howard v. Commissioner of Correction

the plea and imposed a total effective sentence of forty years of incarceration.2 2 The canvass included the following colloquy between the court, the petitioner, and Cohen: ‘‘The Court: Docket ending 678 charges you with the crime of murder, [§] 53a-54a, do you say guilty or not guilty? ‘‘[The Petitioner]: Guilty. ‘‘[Cohen]: And that’s under Alford, Your Honor. ‘‘The Court: And an Alford plea means that you don’t agree with every fact that is going to be alleged against you by the state. But you recognize that if you had a trial, there is substantial likelihood that you would be convicted of this charge. And do you agree that there is the potential for a bigger sentence if you were convicted after trial? Do you agree with that? ‘‘[The Petitioner]: Yes. ‘‘The Court: So, the reason the person says guilty under Alford isn’t because they are admitting every fact in the case against them, but it is because they want to take a plea agreement rather than have a trial. Is that true? ‘‘[The Petitioner]: Yes. ‘‘The Court: Did you take alcohol, medicine, or drugs today that prevents you from understanding the court? ‘‘[The Petitioner]: No, ma’am. ‘‘The Court: Did you talk to Mr. Cohen about your decision to enter into a plea agreement rather than have a trial? ‘‘[The Petitioner]: Yes. ‘‘The Court: And are you satisfied with the information and advice that he gave you? ‘‘[The Petitioner]: Yeah. ‘‘The Court: And you understand it all. Correct? ‘‘[The Petitioner]: Correct. . . . ‘‘The Court: Now, on the [charge of murder] these are the rights that you’ve given up: A right to a trial before a court or before a jury, a right to remain silent, a right to plead not guilty and have the state show that you are guilty beyond a reasonable doubt. At a trial your lawyer is allowed to confront or cross-examine the state’s witnesses. You could testify on your own behalf. You could present a defense if you chose. ‘‘[The Petitioner]: Yes, I understand. ‘‘The Court: Do you understand each of those rights? ‘‘[The Petitioner]: Yes. ‘‘The Court: Has anyone forced you or threatened you in any way to make you enter these pleas? ‘‘[The Petitioner]: No. ‘‘The Court: Are these pleas of your own free will? ‘‘[The Petitioner]: Yes. ‘‘The Court: The maximum sentence or what you owe on probation is seven years and nine months.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Padilla v. Kentucky
559 U.S. 356 (Supreme Court, 2010)
Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Boykin v. Alabama
395 U.S. 238 (Supreme Court, 1969)
North Carolina v. Alford
400 U.S. 25 (Supreme Court, 1970)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Johnson v. Commissioner of Correction
941 A.2d 248 (Supreme Court of Connecticut, 2008)
Crawford v. Commissioner of Correction
982 A.2d 620 (Supreme Court of Connecticut, 2009)
State v. Buhl
138 A.3d 868 (Supreme Court of Connecticut, 2016)
Horn v. Commissioner of Correction
138 A.3d 908 (Supreme Court of Connecticut, 2016)
Flomo v. Commissioner of Correction
149 A.3d 185 (Connecticut Appellate Court, 2016)
Ramos v. Commissioner of Correction
159 A.3d 1174 (Connecticut Appellate Court, 2017)
State v. Abdalaziz
729 A.2d 725 (Supreme Court of Connecticut, 1999)
State v. Johnson
751 A.2d 298 (Supreme Court of Connecticut, 2000)
Carraway v. Commissioner of Correction
72 A.3d 426 (Connecticut Appellate Court, 2013)
Hutterly v. Miller
169 A.3d 795 (Supreme Court of Connecticut, 2017)
Haughey v. Comm'r of Corr.
170 A.3d 1 (Supreme Court of Connecticut, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
236 Conn. App. 506, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howard-v-commissioner-of-correction-connappct-2025.