State of Connecticut v. Samuel M.

Summary

The court held that, once the defendant challenged his automatic transfer to the regular criminal docket based on his age, the state bore the burden of proving that he was at least fourteen when the charged conduct occurred. The evidence did not establish under any burden of proof that the offenses underlying the convictions occurred on or after the defendant's fourteenth birthday, so the court affirmed the order vacating the convictions and directing transfer to the juvenile docket for a new trial. The court also held that review of the legal conclusions underlying a motion to dismiss is de novo, while factual findings concerning the defendant's age are reviewed for clear error.