Connecticut Supreme Court reverses sentence based "materially false information" that defendant was in "mythical group of teenage 'superpredators'"

A few helpful folks made sure I did not miss the notable ruling by the Connecticut Supreme Court this past Friday in State v. Belcher, No. SC 20531 (Conn. Jan 21, 2022) (available here). The start of the unanimous opinion sets out the basics:

The defendant, Keith Belcher, a juvenile offender, appeals from the trial court’s denial of his motion to correct an illegal sentence. After his conviction, the defendant received a total effective sentence of sixty years of incarceration.  He claims, inter alia, that the trial court improperly denied his motion to correct on the basis of the court’s conclusion that the sentencing court did not impose the sentence in an illegal manner by relying on materially false information.

Our review of the record reveals that the defendant established that the sentencing court substantially relied on materially false information in imposing his sentence, specifically, on the court’s view that the defendant was a ‘‘charter member’’ of a mythical group of teenage ‘‘superpredators.’’  Therefore, we conclude that the trial court abused its discretion in denying the defendant’s motion to correct.  Accordingly, we reverse the judgment of the trial court, and the case is remanded with direction to grant the defendant’s motion and for resentencing.

The full opinion merits a full read for many reasons.  Therein, one learns that the defendant here was only 14 when committing his crimes way back in 1993 (meaning he has now already served nearly three decades).  Also of note, the court avoids resolution of constitutional claims by deciding he gets resentencing based on the illegal manner of the original sentence's imposition. Here are a few highlights from the interesting opinion:

We conclude that the superpredator theory was baseless when it originally was espoused and has since been thoroughly debunked and universally rejected as a myth, and it therefore constituted false and unreliable information that a sentencing court ought not consider in crafting a sentence for a juvenile offender....

In the context of the sentencing of the defendant, a Black teenager, the court’s reliance on the materially false superpredator myth is especially detrimental to the integrity of the sentencing procedure for two reasons.  First, reliance on that myth invoked racial stereotypes, thus calling into question whether the defendant would have received as lengthy a sentence were he not Black.  Second, the use of the superpredator myth supported treating the characteristics of youth as an aggravating, rather than a mitigating, factor....

In summary, by invoking the superpredator theory to sentence the young, Black male defendant in the present case, the sentencing court, perhaps even without realizing it, relied on materially false, racial stereotypes that perpetuate systemic inequities — demanding harsher sentences — that date back to the founding of our nation.  In addition, contrary to Roper and its progeny, in relying on the superpredator myth, the sentencing court counted the characteristics of youth as an aggravating factor against the defendant.  Although we do not mean to suggest that the sentencing judge intended to perpetuate a race based stereotype, we cannot overlook the fact that the superpredator myth is precisely the type of materially false information that courts should not rely on in making sentencing decisions.  Whether used wittingly or unwittingly, reliance on such a baseless, illegitimate theory calls into question the legitimacy of the sentencing procedure and the sentence.