Supreme Court denies Mendiola appeal against DOC

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The Supreme Court of Guam has denied the appeal of Carmelo A.Q. Mendiola, Sr. in his case against the Department of Corrections.

Mendiola appealed the trial court’s denial of his Petition for Writ of Habeas Corpus. In the underlying criminal trial, Mendiola was tried for the third time with certain criminal offenses—his first trial having resulted in a conviction later overturned by the Supreme Court for prosecutorial vouching, and his second trial having ended in a hung jury.

In his petition, Mendiola asserted ineffective assistance of counsel based on his trial counsel’s failure to investigate and call a key witness with potentially exculpatory information.

However, the trial court found that trial counsel’s actions were reasonable trial strategy and denied Mendiola’s petition.

Mendiola appealed and the Supreme Court treated the appeal as an original petition for writ of habeas corpus, invoking its original rather than appellate jurisdiction.

In denying Mendiola’s petition, the Supreme Court held that Mendiola did not satisfy the first prong of the test pronounced in Strickland v. Washington, 466 U.S. 668 (1984), because he failed to demonstrate that trial counsel’s specific action or omission of not proffering the witness, under the circumstances as they existed at the time of the action or omission, fell below an objective standard of reasonableness such that the trial cannot be relied on as having produced a just result.