State v. McCleese

Summary

The court held that retroactive parole eligibility under P.A. 15-84 adequately remedies the defendant's juvenile sentencing violation under both the federal and Connecticut constitutions, so his motion to correct an illegal sentence was moot and the trial court lacked subject matter jurisdiction. The court also rejected separation-of-powers, due-process, and equal-protection challenges to the statute, concluding that the legislature could modify the sentencing scheme and rationally distinguish between juvenile offenders sentenced for murder and those sentenced for capital felony. Justice Ecker, dissenting, would have required resentencing because parole eligibility does not remedy the lack of an individualized sentencing hearing addressing youth-related culpability; Justice Palmer, concurring, would reserve a due-process theory for a case in which it is properly raised.