Com. v. Meekins, R.
1354 EDA 2017
| Pa. Super. Ct. | Dec 5, 2017Background
- On Sept. 21, 2014, Meekins assaulted his girlfriend while intoxicated: he grabbed her by the hair, strangled her, threatened to kill her, and she vomited and had visible injuries. Police interrupted the attack and observed Meekins straddling the victim with his hands around her neck.
- Emergency personnel and an ER physician testified about the victim’s injuries, vomiting (with blood), and that she was triaged as a serious emergency; photographs of injuries that night and ten days later were admitted, including a photo of vomit on the victim’s pants.
- A jury convicted Meekins of aggravated assault, simple assault, terroristic threats, reckless endangerment, and the court convicted him of harassment; he was acquitted of attempted murder and a second aggravated assault count.
- Meekins was sentenced to 6 to 20 years. He filed a timely PCRA petition alleging ineffective assistance of trial counsel; after a PCRA hearing the court dismissed the petition and Meekins appealed.
- Meekins’ claims: (1) counsel failed to object to irrelevant/unduly prejudicial testimony and a vomit photograph; (2) counsel failed to object to hearsay (victim’s statement to police that he tried to kill her); (3) counsel inadequately prepared and met with Meekins too few times.
Issues
| Issue | Meekins’ Argument | Commonwealth’s Argument | Held |
|---|---|---|---|
| Counsel failed to object to testimony/photograph about victim’s vomiting and to admission of photograph | Evidence of vomiting and vomit-photo was irrelevant and unduly prejudicial; it inflamed the jury | Evidence was probative of injury and severity; even if admissible, Meekins cannot show prejudice given overwhelming evidence | Denied — no prejudice shown; overwhelming evidence of assault and jury acquitted on more serious charges |
| Counsel failed to object to hearsay (victim’s statement to officer that Meekins tried to kill her) | The statement was inadmissible hearsay and should have been excluded | Statement was admissible/harmless and, in any event, Meekins fails to show prejudice | Denied — Meekins failed to show how exclusion would have changed outcome |
| Counsel inadequate preparation / insufficient meetings with client | More meetings would have uncovered impeachment material about victim’s mental state and aided cross-examination | Trial counsel met with Meekins multiple times; Meekins’ claim is conclusory and unsupported | Waived / Denied — claim conclusory, credibility findings favored counsel; no Strickland showing |
| Overall ineffective assistance under Strickland/Johnson standard | Cumulative trial failures deprived Meekins of a fair trial | Counsel’s conduct had reasonable basis; no prejudice shown | Denied — PCRA court’s dismissal affirmed |
Key Cases Cited
- Commonwealth v. Reyes–Rodriguez, 111 A.3d 775 (Pa. Super. 2015) (standard of review in PCRA appeals)
- Commonwealth v. Johnson, 966 A.2d 523 (Pa. 2009) (PCRA ineffective-assistance elements and prejudice standard)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective assistance test)
- Commonwealth v. Travaglia, 661 A.2d 352 (Pa. 1995) (courts may dispose of ineffectiveness claims on prejudice prong alone)
- Commonwealth v. Loner, 836 A.2d 125 (Pa. Super. 2003) (counsel not ineffective for failing to pursue meritless claim)
- Commonwealth v. Collins, 545 A.2d 882 (Pa. 1988) (deference to reasonable trial strategy)
- Commonwealth v. Ervin, 766 A.2d 859 (Pa. Super. 2000) (ineffectiveness requires approach so unreasonable no competent counsel would choose it)
- Commonwealth v. Pierce, 527 A.2d 973 (Pa. 1987) (reasonableness inquiry for counsel’s strategy)
- Commonwealth v. Clark, 626 A.2d 154 (Pa. 1993) (defendant must show unchosen alternatives offered substantially greater potential for success)
- Commonwealth v. Buksa, 655 A.2d 576 (Pa. Super. 1995) (unsuccessful strategy alone not reversible)
- Commonwealth v. Spotz, 896 A.2d 1191 (Pa. 2006) (ineffectiveness claims are not self-proving)
- Commonwealth v. Thomas, 744 A.2d 713 (Pa. 2000) (bare, nonspecific allegations of ineffectiveness insufficient)
- Commonwealth v. Rolan, 964 A.2d 398 (Pa. Super. 2008) (failure to address Strickland prongs defeats claim)
- Commonwealth v. Orlando, 156 A.3d 1274 (Pa. Super. 2017) (deference to PCRA court credibility findings)