State v. Hatch

816 A.2d 712, 75 Conn. App. 615, 2003 Conn. App. LEXIS 108
CourtConnecticut Appellate Court
DecidedMarch 18, 2003
DocketAC 22164
StatusPublished
Cited by3 cases

This text of 816 A.2d 712 (State v. Hatch) 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
State v. Hatch, 816 A.2d 712, 75 Conn. App. 615, 2003 Conn. App. LEXIS 108 (Colo. Ct. App. 2003).

Opinion

Opinion

PETERS, J.

This case concerns the validity of a plea agreement. The issue is whether a plea is knowing and [616]*616voluntary if the defendant is not informed, at the time of the plea hearing, that his contemplated period of probation would require compliance with special conditions. This is an issue of first impression. Although we conclude that a defendant must be apprised of these conditions when entering a guilty plea, we affirm the judgment of the trial court because the court had no duty itself to inform the defendant of his ability to withdraw the plea.

The state charged the defendant, Edward T. Hatch, with larceny in the sixth degree pursuant to General Statutes § 53a-125b.1 On October 12,2000, the defendant entered a plea of guilty to the larceny count and to being a persistent offender pursuant to General Statutes (Rev. to 1999) § 53a-40 (c), now (e). At that time, the court formally accepted the plea bargain and advised the defendant that he would be required to serve five years of incarceration, suspended, and three years of probation.

The trial court deliberately stayed the sentencing proceeding from October to April to give the defendant the opportunity to demonstrate his eligibility for probation by remaining in drug counseling and providing urine samples. The defendant remained drug free during this period.

At the sentencing hearing, the court informed the defendant that his probation was subject to the “condition of regular probation, which mostly every defendant in the state gets.” The court then imposed the following conditions on the defendant’s probation: (1) the defendant would be required to continue his drug treatment; and (2) the defendant would be required to provide [617]*617random urine samples for drug testing. This was the first time that the defendant was informed of these conditions to his probation. The defendant immediately protested, but did not move to withdraw his guilty plea.

In this appeal, the defendant maintains that the trial court’s belated disclosure of these special conditions violated his constitutional right to due process. The fact that the court denominated these conditions as standard provisions does not make them so. The state agrees with the defendant that conditions of drug testing and treatment are special conditions of probation.2 See State v. Durkin, 219 Conn. 629, 631, 595 A.2d 826 (1991); State v. Thorp, 57 Conn. App. 112, 114, 747 A.2d 537, cert. denied, 253 Conn. 913, 754 A.2d 162 (2000); State v. Gaston, 56 Conn. App. 125, 126 n.1, 741 A.2d 344 (1999).

The defendant does not challenge the authority of the court to add special conditions to his probation. See General Statutes (Rev. to 1999) § 53a-30 (a) (13), now (16). He claims, instead, that he should have been informed of these conditions at the time of the plea hearing rather than at the time of the sentencing hearing. Because of the delay in receiving this important information, he maintains that the trial court, after hearing the defendant’s objection at the sentencing hearing, should have advised him of his right to withdraw his plea pursuant to the provisions of Practice Book §§ 39-26 and 39-27.3

[618]*618Before we can address the merits of the defendant’s claim, however, we must determine whether his claim is properly before us. Ordinarily, a defendant who challenges the propriety of a sentence should move to withdraw his guilty plea. Practice Book § 39-26; State v. Badgett, 220 Conn. 6, 16, 595 A.2d 851 (1991); State v. Webb, 62 Conn. App. 805, 810, 772 A.2d 690 (2001). Because the defendant did not do so, he arguably failed to preserve his claim before the trial court. We nonetheless can address his claim if it qualifies for appellate review under State v. Golding, 213 Conn. 233, 239-40, 567 A.2d 823 (1989).4 We conclude that it does not.

“Under the Golding doctrine, a defendant can prevail on a claim of constitutional error not preserved at trial [619]*619only if all of the following conditions are met: (1) the record is adequate to review the alleged claim of error; (2) the claim is of constitutional magnitude alleging the violation of a fundamental right; (3) the alleged constitutional violation clearly exists and clearly deprived the defendant of a fair trial; and (4) if subject to harmless error analysis, the state has failed to demonstrate harmlessness of the alleged constitutional violation beyond a reasonable doubt.” (Emphasis in original; internal quotation marks omitted.) State v. Gordon, 69 Conn. App. 691, 695, 796 A.2d 1238 (2002).

The defendant’s claim meets two of the Golding requirements. The record is adequate for our review. The propriety of a guilty plea implicates a defendant’s due process rights. Boykin v. Alabama, 395 U.S. 238, 243, 89 S. Ct. 1709, 23 L. Ed. 2d 274 (1969); State v. Andrews, 253 Conn. 497, 502-503, 752 A.2d 49 (2000). We must, therefore, determine whether a due process violation clearly exists. See State v. Golding, supra, 213 Conn. 239-40. This is the central inquiry in most Golding cases.

The crux of the defendant’s claim of a due process violation is that he had no way of knowing, at the time he entered his guilty plea, that his probation would be subject to the special conditions attached by the court. See State v. Andrews, supra, 253 Conn. 502-503. In his view, it was reasonable for him to expect to be bound by the standard conditions of probation that are set out in § 53a-30.5 He argues, however, that it was not [620]*620reasonable for him to be bound by conditions relating to drug treatment and testing that are not listed as standard or special conditions in our statutes.

Our inquiry is twofold. We must first determine whether a court must disclose to a person who contemplates pleading guilty the nonstandard conditions of probation that he will face at the time of sentencing. We must then determine whether, if a court has not made such a disclosure before the time of sentencing, it must apprise the defendant of his right to withdraw his guilty plea.

I

It is hornbook law that a plea of guilty does not pass constitutional muster if the plea is not knowing and voluntary.6 Id. At the time of taking a plea bargain, a court is obligated to inform a defendant of four constitutional rights that are waived by a guilty plea.7 Practice Book [621]*621§ 39-19 (5); State v. Andrews, supra, 253 Conn. 503.

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Related

State v. Das
968 A.2d 367 (Supreme Court of Connecticut, 2009)
State v. Mordasky
853 A.2d 626 (Connecticut Appellate Court, 2004)
State v. Hatch
822 A.2d 244 (Supreme Court of Connecticut, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
816 A.2d 712, 75 Conn. App. 615, 2003 Conn. App. LEXIS 108, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hatch-connappct-2003.