Paul Christopher Hildwin v. State of Florida, 141 So. 3d 1178

Background

Victim Vronzettie Cox was found raped and strangled in the trunk of her car; blue jean shorts with semen-encrusted women's underwear and a white washcloth were recovered from the car's backseat laundry bag.
At trial the State's serological evidence showed the semen and saliva came from a nonsecretor; Hildwin was a nonsecretor and Haverty (the victim’s boyfriend) was a secretor, so the State argued the biological material was consistent with Hildwin and inconsistent with Haverty.
Hildwin was convicted of first-degree murder and sentenced to death; he contended at trial that Haverty committed the murder.
Postconviction DNA testing (and subsequent CODIS/database comparison) excluded Hildwin and identified the DNA on both items as matching Haverty.
The postconviction court denied relief, finding potential admissibility problems and concluding the new DNA evidence would not likely produce an acquittal given the other circumstantial and direct evidence.
The Florida Supreme Court reversed: it held the newly discovered DNA (identifying Haverty) materially undermines the State’s trial theory, must be considered cumulatively with all admissible evidence, and compels a new trial; conviction and death sentence vacated.

Issues

Issue	Hildwin's Argument	State's Argument	Held
Whether newly discovered DNA evidence satisfies Rule 3.851(d)(2)(A) / Jones two‑prong test	New DNA (matching Haverty) was previously unknowable and, when added to the record, weakens the State’s case enough to give rise to reasonable doubt and therefore entitles Hildwin to a new trial	The DNA would likely be inadmissible or, even if admitted, would not probably produce an acquittal given strong circumstantial evidence against Hildwin	Court: DNA was newly discovered, admissible, and when considered cumulatively with trial and postconviction evidence, would probably produce acquittal; vacated conviction and sentence and remanded for new trial
Admissibility of the FDLE DNA report / physical items on retrial	The underwear and washcloth were already admitted at trial; authentication, relevance, chain‑of‑custody issues are jury questions and do not bar admissibility of the DNA identification	Postconviction court: discrepancies (e.g., description of the “white rag”), chain of custody, and predicate issues could render the washcloth evidence inadmissible	Court: the items were admitted at trial; authentication, relevance, and chain issues do not justify exclusion now—admissibility is for trial/jury, so the DNA evidence should be considered
Proper standard and scope for evaluating newly discovered evidence	Court must apply Jones II and conduct a cumulative analysis of the newly discovered evidence together with all admissible trial and postconviction evidence to assess probability of acquittal	The postconviction court properly weighed evidence and could reject relief because DNA did not create reasonable doubt in context	Court: reaffirmed Jones II cumulative approach (including evidence from prior postconviction proceedings) and found postconviction court failed to apply it properly; reversed
Whether vacatur of death sentence is required if conviction vacated	If conviction vacated on grounds warranting a new trial, death sentence likewise vacated and case remanded	State argued even without the DNA evidence it could still convict and that sentencing error not shown	Court: vacated both conviction and death sentence and remanded for new trial

Key Cases Cited

Jones v. State, 709 So.2d 512 (Fla. 1998) (defines two‑prong test for newly discovered evidence and standard that evidence must "give rise to a reasonable doubt")
Jones v. State, 678 So.2d 309 (Fla. 1996) (explains reasonable‑doubt formulation for new evidence claims)
Jones v. State, 591 So.2d 911 (Fla. 1991) (original Jones standard on newly discovered evidence and sentencing implications)
Lightbourne v. State, 742 So.2d 238 (Fla. 1999) (requires cumulative review of all evidence, including some postconviction‑developed evidence)
Swafford v. State, 125 So.3d 760 (Fla. 2013) (reiterates cumulative analysis and that excluded or postconviction evidence may be considered)
Marek v. State, 14 So.3d 985 (Fla. 2009) (summarizes newly discovered evidence test and standards)
Green v. State, 975 So.2d 1090 (Fla. 2008) (standard of review for postconviction factual findings and legal application)
Robinson v. State, 770 So.2d 1167 (Fla. 2000) (requires consideration of newly discovered evidence together with evidence from prior hearings)
Hildwin v. State, 531 So.2d 124 (Fla. 1988) (direct‑appeal opinion summarizing trial evidence)
Hildwin v. State, 951 So.2d 784 (Fla. 2006) (prior postconviction decision addressing serology/DNA developments)