State v. Kelley

In State v. Kelley, 206 Conn. 323, 537 A.2d 483, 537 A.2d 490 (1988), the court held that the transfer of a child from the docket of juvenile matters to the regular criminal docket of the Superior Court did not implicate the court's subject matter jurisdiction. Id. at 332. Although the legislature preserved a separate system for the disposition of cases involving juveniles accused of criminal acts, the court stated that the juvenile docket was not vested with subject matter jurisdiction separate and distinct from that of the Superior Court. Id. at 331. The court concluded that "rather than implicating subject matter jurisdiction, issues relating to transfers between the juvenile and the regular criminal docket involve considerations that are analogous to those of the law of venue. It is a well established rule that, outside the area of administrative appeals, venue is not a jurisdictional but a procedural question; consequently, venue, unlike subject matter jurisdiction, can be waived by the parties." Id. at 332.