State v. Evans

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The Supreme Court held that its decision in State v. Ray, 966 A.2d 148 (Conn. 2009), remained good law in light of the subsequent decision of the United States Supreme Court in Alleyne v. United States, 570 U.S. 99 (2013) and the legislature’s recent amendment of Conn. Gen. Stat. 21a-278(b).On appeal from the trial court’s judgment denying his motion to correct an illegal sentence, Defendant argued that the Supreme Court should overruled its interpretation of section 21a-278(b) in Ray. The Supreme Court disagreed with the merits of Defendant’s claims and affirmed the judgment of the trial court, holding (1) Ray remains good law in the wake of Alleyne; (2) recent amendments did not change this Court’s long-standing interpretation of section 21a-278(b) making drug dependency an affirmative defense that, if proven, reduces a defendant’s potential sentence; (3) construing drug dependency as an affirmative defense under section 21a-278(b) does not violate separation of powers; and (4) accordingly, the trial court properly denied Defendant’s motion to correct an illegal sentence. View "State v. Evans" on Justia Law