State v. Brown
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Defendant was convicted of multiple offenses and sentenced to a term of incarceration followed by sixteen years of special parole. Defendant filed a motion to correct an illegal sentence, arguing that the trial court illegally sentenced him to a sixteen year term of special parole when, in light of the crimes at issue, the maximum terms of special parole was ten years. The trial court denied the motion. The appellate court reversed, concluding that the two consecutive sentences of special parole at issue - neither of which exceeded ten years individually but together imposed a total effective sentence of sixteen years of special parole - violated Conn. Gen. Stat. 54-125e(c), which operates as an aggregate limitation on the total effective sentence of special parole when a defendant is sentenced for multiple offenses. The Supreme Court reversed, holding that the ten year limitation on a period of special parole provided for in section 54-125e(c) applies per offense, rather than to the total effective sentence of special parole. Remanded.
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