State v. Roberts

── State v. Roberts ── Court: Supreme Court of Connecticut Date: April 28, 2026 Author: Mullins Category: General ************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopinion motions and petitions for certification is the “officially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************  State v. Roberts STATE OF CONNECTICUT v. DAVID D. ROBERTS (SC 21061) Mullins, C. J., and McDonald, D’Auria, Ecker, Alexander, Dannehy and Bright, Js. Syllabus The defendant appealed, on the granting of certification, from the judg- ment of the Appellate Court, which had affirmed his conviction, on pleas of guilty, of reckless endangerment in the second degree, threatening in the first degree, and intimidation based on bigotry or bias in the third degree. The defendant claimed that the Appellate Court had improperly upheld the trial court’s denial of his motion to withdraw his pleas because, during the plea canvass, the trial court did not specifically ask him whether he was knowingly and voluntarily waiving his constitutional rights to a jury trial, to confront his accusers, and against self-incrimination, which he claimed was required by Boykin v. Alabama (395 U.S. 238). Held: The Appellate Court properly upheld the trial court’s denial of the defen- dant’s motion to withdraw his pleas, as the plea canvass of the defendant in this case was constitutionally adequate, even though it presented a very close question and was contrary to best practices. Boykin requires only that the record affirmatively disclose that a defendant has entered his plea knowingly and voluntarily for the plea to be constitution- ally valid, and there is no requirement that a plea canvass include enumeration of each of the three constitutional rights identified in Boykin. Moreover, in order to determine whether a defendant’s guilty plea was knowing and voluntary, a reviewing court must consider the totality of the circumstances surrounding the plea canvass, and, under the totality of the circumstances of the present case, the plea canvass of the defendant was constitutionally adequate. Specifically, during the plea canvass, the defendant confirmed that counsel had explained to him the rights that he was waiving by pleading guilty, that he had been afforded enough time to speak with counsel about his decision to plead guilty, and that he was satisfied with counsel’s representation, all of which were sufficient to demonstrate the defendant’s understanding of the consequences of his guilty pleas and the waiver of his constitutional rights, thus rendering his pleas knowing and voluntary. Moreover, defense counsel was present during the canvass and stated that he was not aware of any reason that the trial court should not accept the guilty pleas, and the trial court mentioned the d