Pruett, Robert Lynn
WR-62,099-03
| Tex. App. | Apr 2, 2015Background
- Pruett seeks a writ of prohibition to halt his April 28, 2015, execution based on alleged Eighth and Fourteenth Amendment violations.
- Trial evidence included eyewitness testimony of Pruett’s murder of correctional officer Nagle in Three Building, December 17, 1999.
- DNA testing post-trial yielded mostly inconclusive results; one allele at one locus was reported but deemed insufficient for a match.
- Storage guidelines for evidence were published years after the trial, and there is no proven harm or loss of evidence in the record.
- The State argues substantial non-DNA evidence supports guilt; Pruett argues possible constitutional harm from evidence handling and DNA testing delays.
- The court denies the writ, finding no constitutional violations and that post-trial DNA would not have altered the verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence storage guidelines violated constitutional rights | Pruett asserts improper storage violated rights | State claims no proven harm and guidelines postdate trial | No constitutional violation; no proven harm |
| Whether post-trial DNA could have changed the verdict | Pruett contends DNA testing could exonerate him | DNA results were inconclusive and would not have altered guilt | DNA inconclusive; likely would not have changed verdict |
| Whether the incentives and alleged misconduct by officials prejudiced Pruett | Pruett claims conspiratorial misconduct and manipulation | No evidence of wrongdoing; allegations lack support | No evidence of constitutional violation; no relief |
Key Cases Cited
- Whitaker v. State, 160 S.W.3d 5 (Tex. Crim. App. 2004) (other evidence can support guilt and diminish need for post-trial DNA testing)
- State v. Holloway, 329 S.W.3d 247 (Tex. App.—Texarkana 2010) (affirmed 360 S.W.3d 480; substantial other evidence supports death causation)
- Bell v. State, 90 S.W.3d 301 (Tex. Crim. App. 2002) (presence of another DNA donor does not automatically negate guilt)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment standards and evolving decency)