State v. Williams-BeyAnnotate this Case
The Supreme Court affirmed the decision of the Appellate Court affirming the trial court's dismissal of Defendant's motion to correct an illegal sentence, holding that because Defendant is now eligible for parole under No. 15-84 of the 2015 Public Acts (P.A. 15-84) the Connecticut constitution did not require a resentencing of his unconstitutional sentence.
Defendant, a juvenile offender, was convicted of murder and sentenced to thirty-five years' imprisonment. At the time of sentence, Defendant was indelible for parole. Thereafter, decisions by the United States and Connecticut Supreme Courts and enactments by the legislature resulted in changes to the sentencing scheme for juvenile offenders. To comply with federal constitutional requirements the legislature passed P.A. 15-84. As a result, Defendant will be parole eligible after serving twenty-one years. Thereafter, Defendant filed a motion to correct an illegal sentence, asserting a violation of Miller v. Alabama, 467 U.S. 460 (2012). The trial court dismissed the motion for lack of jurisdiction. The Appellate Court ultimately affirmed on the ground decided in State v. Delgado, 151 A.3d 345 (Conn. 2016). The Supreme Court affirmed, holding that, consistent with Delgado and the federal constitution, Defendant's parole eligibility afforded by P.A. 15-84, 1 was an adequate remedy for the Miller violation.