Thomas v. Chappell

When a defense attorney unreasonably fails to investigate and locate witnesses to corroborate a witness’s critical testimony and support the primary defense strategy of third-party culpability in a difficult-to-decide case, such performance prejudices the defendant.

Ralph International Thomas was convicted of murdering Greg Kniffin and Mary Gioia. At his initial trial, the prosecution presented circumstantial evidence to the jury, and did not present a motive, a murder weapon, or physical evidence directly linking Thomas to the crime. The defense attorney, James Chaffee, adopted a primary defense strategy of providing an alternate theory for who committed the murders. Chaffee called only one witness, a homeless woman named Vivian Cercy. Cercy provided information about another possible suspect; however, Chaffee provided no evidence or witnesses to corroborate Cercy’s story. The jury deliberated for nearly 5 full days, indicating a difficult decision, and the jury requested readbacks of Cercy’s testimony. The jury found Thomas guilty and he was sentenced to death. Thomas filed a state habeas petition with the California Supreme Court, alleging ineffective assistance counsel due to Chaffee’s failure to investigate witnesses to corroborate Cercy’s testimony. The California Supreme Court held that Chaffee’s inquiries were unreasonably deficient, but that Chaffee’s performance did not prejudice Thomas. Thomas then filed a federal habeas petition. The district court ruled that Chaffee’s failure to find additional witnesses constituted constitutionally deficient performance that prejudiced Thomas. On appeal, the Ninth Circuit found that the corroborating evidence could have reasonably altered the outcome of the case, because the original case against Thomas was circumstantial, the jury was conflicted about Thomas’s guilt, and the jury’s conflict hinged on Cercy’s story. Had Chaffee conducted a reasonable investigation, he would have found at least three of eleven potential witnesses to corroborate Cercy’s critical testimony, thereby creating a reasonable doubt as to Thomas’s guilt. Therefore, the Court held that Chaffee’s deficient representation prejudiced Thomas in his initial trial. AFFIRMED.