Supreme Court of Connecticut
State v. King
February 28, 2023346 Conn. 238
Summary
The court held that an out-of-state conviction qualifies for Connecticut's repeat-offender sentencing enhancement when the offenses' essential elements are the same to a considerable degree. Applying that rule, the court determined that Florida's actual-physical-control element is substantially the same as Connecticut's operating element because both require an action placing an intoxicated person in a position to operate the vehicle, although neither requires that the vehicle be moving or the engine running. The court therefore affirmed the enhanced sentence.