Meletrich v. Commissioner of Correction
212 A.3d 678
| Conn. | 2019Background
- Petitioner Angel Meletrich was convicted of first‑degree robbery, larceny, and related conspiracy counts based largely on testimony that his cousin Bethza Meletrich unlocked a side door and aided the robbery; physical evidence (masks, gloves, register drawers) and DNA tied petitioner to items seized from his home near the restaurant.
- Trial counsel, Attorney Claud Chong, pursued an alibi defense and called petitioner’s girlfriend Christina Diaz, who testified she spent the entire day and night with petitioner and that he never left the house.
- Petitioner later filed a habeas petition claiming ineffective assistance for Chong’s failure to call a second alibi witness, his aunt Guillermina Meletrich, who at the habeas trial testified she came home ~4:30 pm and saw petitioner at various times that night but could not account for his whereabouts continuously.
- Chong testified he interviewed several relatives and concluded Diaz was the strongest alibi witness because she could testify petitioner was in bed at the specific time of the robbery; other family members could not account for petitioner at every critical moment.
- The habeas court denied relief and certification to appeal; the Appellate Court dismissed the appeal. The Connecticut Supreme Court granted certification limited to whether counsel’s failure to call Guillermina was deficient and prejudicial, and affirmed the Appellate Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for not calling aunt Guillermina as a second alibi witness | Meletrich: Guillermina would corroborate Diaz and bolster alibi/cast doubt on conspiracy evidence | State/Chong: Strategic choice to present only Diaz, who alone could account for petitioner at the specific robbery time; Guillermina could not account continuously and might be harmful | Held: Not ineffective; counsel’s choice was reasonable strategy because Guillermina could not sufficiently account for petitioner during critical timeframes |
| Whether omission prejudiced petitioner (reasonable probability of different outcome) | Meletrich: Additional corroboration would make jurors more likely to believe alibi and reject conspiracy theory | State: Even if called, Guillermina’s limited, intermittent observations plus proximity of crime scene meant jury could infer petitioner left unnoticed; no reasonable probability of different verdict | Held: Court did not reach full prejudice analysis after finding no deficient performance; appeal certification properly denied |
| Whether Guillermina was a neutral, corroborative witness like in Skakel | Meletrich: Guillermina is necessary neutral corroboration to counter potential bias of Diaz | State: Guillermina was related to petitioner and codefendants and thus not neutral; her testimony would be cumulative | Held: Distinguishable from Skakel; Guillermina was not neutral and her testimony would be cumulative and not sufficiently helpful |
| Whether counsel’s failure to investigate/explain decision rendered strategy unreasonable | Meletrich: Chong could not articulate reasons so decision was unexplained and unreasonable | State: Chong investigated multiple family members and reasonably concluded Diaz was strongest; he articulated his judgment at habeas | Held: Counsel provided a plausible, strategic reason; strong deference applies and performance not deficient |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑prong standard for ineffective assistance: performance and prejudice)
- Skakel v. Commissioner of Correction, 329 Conn. 1 (Conn. 2018) (neutral, independent alibi witness may be critical to overcome family witness bias)
- Johnson v. Commissioner of Correction, 330 Conn. 520 (Conn. 2019) (decision not to call family alibi witness reasonable where witness could not continuously account for defendant and crime scene was close)
- Jackson v. Commissioner of Correction, 149 Conn. App. 681 (Conn. App. 2014) (failure to call additional alibi witnesses not deficient when they could not account for defendant at the exact time of the crime)
- Spearman v. Commissioner of Correction, 164 Conn. App. 530 (Conn. App. 2016) (declining to fault counsel for not calling family alibi witnesses who would place defendant near scene and could not establish continuous alibi)
- Gaines v. Commissioner of Correction, 306 Conn. 664 (Conn. 2012) (counsel ineffective where there was no investigation of known alibi witnesses who could have testified)
- Bryant v. Commissioner of Correction, 290 Conn. 502 (Conn. 2009) (counsel’s failure to call independent, contemporaneous witnesses can be deficient when their statements would raise reasonable doubt)