State v. Rivas

233 Conn. App. 506
CourtConnecticut Appellate Court
DecidedJuly 1, 2025
DocketAC47400
StatusPublished

This text of 233 Conn. App. 506 (State v. Rivas) 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. Rivas, 233 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 State v. Rivas

STATE OF CONNECTICUT v. SAMUEL A. RIVAS, JR. (AC 47400) Alvord, Westbrook and Wilson, Js.

Syllabus

Convicted, following a conditional plea of nolo contendere, of the crime of operating a motor vehicle while under the influence of alcohol or drugs, the defendant appealed. He claimed, inter alia, that the trial court improperly denied his motion to dismiss because the state’s seven month delay in executing its arrest warrant violated his right to due process. Held:

The trial court properly denied the defendant’s motion to dismiss, as the defendant failed to present the court with a sufficient factual record to demonstrate that he suffered actual, substantial prejudice as a result of the state’s preaccusation delay and, thus, a violation of his right to due process..

The prosecution of the defendant for operating a motor vehicle while under the influence of alcohol or drugs did not violate his prior plea agreement with the state as to a charge of interfering with an officer that arose out of the same criminal incident, the defendant having presented no evidence to establish a reasonable belief that the plea agreement had terminated all of his criminal liability flowing from his conduct during that same incident. Argued April 14—officially released July 1, 2025

Procedural History

Information charging the defendant with the crime of operating a motor vehicle while under the influence of alcohol or drugs and with improper use of a registra- tion, brought to the Superior Court in the judicial dis- trict of New London, geographical area number twenty- one, where the court, Hon. Arthur C. Hadden, judge trial referee, denied the defendant’s motion to dismiss; thereafter, the defendant was presented to the court, Hon. Arthur C. Hadden, judge trial referee, on a condi- tional plea of nolo contendere to the charge of operating a motor vehicle while under the influence of alcohol or drugs; judgment of guilty; subsequently, the state entered a nolle prosequi as to the remaining charge, and the defendant appealed to this court. Affirmed. 0, 0 CONNECTICUT LAW JOURNAL Page 1

0 Conn. App. 1 ,0 3 State v. Rivas

Ruth Burke, deputy assistant public defender, with whom, on the brief, was Jennifer Bourn, chief of legal services, for the appellant (defendant). Rebecca R. Zeuschner, deputy assistant state’s attor- ney, with whom, on the brief, were Paul J. Narducci, state’s attorney, and Sarah Bowman, assistant state’s attorney, for the appellee (state). Opinion

WESTBROOK, J. The defendant, Samuel A. Rivas, Jr., appeals from the judgment of conviction rendered following his conditional plea of nolo contendere to the charge of operating a motor vehicle while under the influence of alcohol or drugs in violation of General Statutes § 14-227a.1 On appeal, he claims that the trial court improperly denied his motion to dismiss the charge because (1) the state’s delay in executing the warrant for his arrest (preaccusation delay) violated his right to due process, and (2) the prosecution violated an earlier plea agreement he had entered into with the state.2 We disagree and, accordingly, affirm the judg- ment of the court. 1 General Statutes § 14-227a provides in relevant part: ‘‘(a) . . . No person shall operate a motor vehicle while under the influence of intoxicating liquor or any drug or both. A person commits the offense of operating a motor vehicle while under the influence of intoxicating liquor or any drug or both if such person operates a motor vehicle (1) while under the influence of intoxicating liquor or any drug or both, or (2) while such person has an elevated blood alcohol content. . . .’’ The defendant also was charged with improper use of a registration in violation of General Statutes § 14-147 (c). The state entered a nolle prosequi as to that charge. 2 In his principal appellate brief, the defendant sets forth three claims: the trial court improperly (1) declined to rely on representations by counsel and information in the court file in considering whether the preaccusation delay violated his due process rights; (2) failed to conclude that the preaccu- sation delay violated his due process rights; and (3) determined that the prosecution did not violate the defendant’s prior plea agreement. Because the first two claims are sufficiently interrelated, for ease of discussion, we address those claims together. Page 2 CONNECTICUT LAW JOURNAL 0, 0

4 ,0 0 Conn. App. 1 State v. Rivas

The following facts, as stated by the prosecutor at the time that the defendant entered his conditional plea of nolo contendere, and procedural history are relevant to this appeal. ‘‘[On] March [3, 2022], [at] approximately 10:30 p.m., officers . . . observed a gray Lexus stuck sideways . . . in the middle of the roadway. A check revealed that the registration did not belong to that type of vehicle. Emergency lights were initiated . . . [and] officers approached the operator side of the vehicle. They observed a male later identified as this defendant seated in the driver’s seat, keys in the ignition, [and the] engine on. Officers knocked on the driver’s side window. The [defendant] opened the door. He looked at the police officers. Officers observed his eyes to be bloodshot and glossy. ‘‘[The] defendant started to exit the vehicle. Immedi- ately, officers asked him to stay in the driver’s seat. He continued to stand up and get out of the vehicle. Officers observed the defendant to be off balance and confused, [he] stated, what, and puffed out his chest [and] then made a fist with both of his hands. His speech was slow, slurred, and incoherent at times. Officers attempted to talk to the defendant and gather details of what was going on; however, the defendant was very agitated [and] appeared to stare off in the distance. Again, the defendant put his hands in the front pocket of his hooded sweatshirt. He was asked to remove his hands. He did not comply. ‘‘The defendant walked toward the officers, stood immediately in front of [one officer], appeared disori- ented, and had difficulty with speech. At that time, he then stated to the officer . . . I run this shit, made a fist with his hands, and swung at the officer in an attempt to punch the officer in his face. At that time, other officers attempted to subdue this defendant. The defen- dant continued to resist the officers as he tensed his 0, 0 CONNECTICUT LAW JOURNAL Page 3

0 Conn. App. 1 ,0 5 State v. Rivas

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Bluebook (online)
233 Conn. App. 506, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-rivas-connappct-2025.