Meletrich v. Commissioner of Correction, 174 A.3d 824

Petitioner Angel Meletrich was convicted of first‑degree robbery, conspiracy to commit robbery, first‑degree larceny and conspiracy to commit larceny for a McDonald’s robbery; jury found him guilty at least as a coconspirator under vicarious liability.
Physical and forensic evidence tied the residence at 20 Acorn Street to the crime: masks, gloves, cash register drawers, and DNA/palmprints linking petitioner and co‑defendants.
At trial petitioner presented an alibi witness, Christina Diaz (his girlfriend/ex‑wife), who testified she was with him continuously from before sunset through the time of the robbery.
The petitioner later asserted his aunt, Guillermina Meletrich, would have testified he was at home from about 4:30 p.m. onward and thus provided an additional alibi covering the period when an alleged pre‑robbery confrontation occurred.
Petitioner filed a habeas petition claiming trial counsel (Attorney Claud Chong) was ineffective for failing to call the aunt as an additional alibi witness; the habeas court denied relief and denied certification to appeal.
On appeal the Connecticut Appellate Court affirmed dismissal, holding counsel’s decision was reasonable and any aunt testimony would have been cumulative and insufficient to establish prejudice or a complete alibi.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether habeas court abused discretion by denying certification to appeal	Meletrich: issue is debatable among jurists; certification should be granted	State: claim lacks merit because counsel was not deficient and no prejudice shown	Denied — no abuse; underlying claim not debatable among reasonable jurists
Whether trial counsel was ineffective for not calling aunt as alibi witness (performance prong)	Meletrich: aunt would have testified he was home from ~4:30 p.m., covering the time of alleged conspiracy and robbery	State: counsel investigated, chose Diaz as strongest alibi; aunt’s testimony was cumulative and limited	Not deficient — counsel reasonably relied on Diaz and had tactical basis to omit aunt
Whether omission prejudiced the defense (prejudice prong)	Meletrich: additional testimony would have created reasonable doubt on conspiracy timing and guilt	State: aunt was not fully neutral, testimony not airtight, jury could infer conspiracy formed earlier; other strong forensic and testimonial evidence supported conviction	No prejudice — addition of aunt’s testimony would not likely have changed outcome

Strickland v. Washington, 466 U.S. 668 (effective assistance standard for performance and prejudice)
Simms v. Warden, 229 Conn. 178 (Connecticut standard for reviewing denial of certification to appeal)
Spearman v. Commissioner of Correction, 164 Conn. App. 530 (standards for ineffective assistance review in Connecticut)
Bryant v. Commissioner of Correction, 290 Conn. 502 (importance of neutral, disinterested witness credibility)
Horn v. Commissioner of Correction, 321 Conn. 767 (cumulative evidence doctrine)
Gaines v. Commissioner of Correction, 306 Conn. 664 (duty to investigate vs. reasonable tactical limiting of investigation)
Harrington v. Richter, 562 U.S. 86 (deference to counsel’s strategic choices)
Jackson v. Commissioner of Correction, 149 Conn. App. 681 (alibi insufficiency when it omits critical time periods)
State v. Talton, 197 Conn. 280 (requirements when defendant alleges counsel failed to call known witness)