Ralph Daniel Wright, Jr. v. State of Florida, 221 So. 3d 512

Background

In 2003–2007 Ralph “Ron” Wright had a relationship with Paula O’Conner; Paula bore a son, Alijah, in 2006. Wright repeatedly denied paternity; a paternity complaint was served June 12, 2007.
On July 6, 2007, Paula and fifteen‑month‑old Alijah were found asphyxiated at Paula’s home. Investigators quickly identified Wright as a primary suspect but did not arrest him until December 2008.
A single black Nomex military glove was found on the couch; glove DNA testing produced mixed and conflicting results across FDLE, the State’s private lab (Bode), and the defense expert (DDC). Some tests excluded Wright; some did not.
No fingerprints, footprints, blood, murder weapon, cell‑tower or eyewitness evidence tied Wright to the scene; Wright had no verifiable alibi between ~2:00 a.m. and 7:54 a.m. the morning of the murders, when video shows him at a Starbucks.
The State’s case relied on motive (avoid child support/divorce; maintain lifestyle), opportunity (possible travel time), and exclusion of other suspects; defense emphasized investigative gaps and potential alternative suspects (notably Paula’s daughter Tori, who stood to collect substantial life insurance proceeds).
At trial Wright was convicted of two counts of first‑degree murder and sentenced to death; on direct appeal the Florida Supreme Court reversed, vacated the death sentences, and ordered judgments of acquittal for insufficient evidence.

Issues

Issue	State's Argument	Wright's Argument	Held
Sufficiency of evidence to prove identity and guilt beyond reasonable doubt in a wholly circumstantial case	Motive + opportunity + glove and timing make guilt probable; Wright could have been near scene and then at Starbucks	Evidence is circumstantial, equivocal, and does not exclude reasonable hypotheses of innocence; no direct tie to scene	Reversed: evidence insufficient; convictions vacated and judgments of acquittal ordered
Weight and significance of DNA on the glove	DNA mixtures on glove could include Wright; glove could be linked to MacDill and Wright had access to similar gloves	DNA results were inconsistent across labs; key tests excluded Wright; shared alleles with son (Alijah) and possible prior contact explained findings	Court: DNA was equivocal and did not establish Wright’s contribution or link to the murders; cannot sustain conviction when inferences must be stacked
Application of the special circumstantial‑evidence (reasonable‑hypothesis‑of‑innocence) standard	Even if circumstantial, State argues other evidence makes defendant’s innocence unreasonable	Wright invokes the special standard: circumstantial proof must exclude reasonable hypotheses of innocence	Court applied the special standard and found State failed to exclude reasonable alternative hypotheses (e.g., Tori or others)
Adequacy of investigation and whether alternative suspects were properly excluded	State emphasized investigation focused on Wright as primary suspect and sought to discredit other suspects	Defense argued police failed to investigate plausible alternative suspects (unexamined alibis, untested DNA for Tori, unasked questions about insurance spending)	Court observed investigative gaps and concluded those gaps left reasonable hypotheses of innocence unexcluded, undermining conviction

Key Cases Cited

Dausch v. State, 141 So.3d 513 (Fla. 2014) (explains limits of DNA evidence and when circumstantial proof may be insufficient)
Hodgkins v. State, 175 So.3d 741 (Fla. 2015) (reversed where DNA was the sole connection and alternative access theories existed)
Ballard v. State, 923 So.2d 475 (Fla. 2006) (articulates that suspicions alone cannot sustain a conviction)
Lindsey v. State, 14 So.3d 211 (Fla. 2009) (describes special circumstantial‑evidence standard requiring exclusion of reasonable hypotheses of innocence)
Baugh v. State, 961 So.2d 198 (Fla. 2007) (rejects convictions based on impermissibly stacked inferences)
Miller v. State, 770 So.2d 1144 (Fla. 2000) (circumstantial‑evidence test guards against pyramiding assumptions)
Johnston v. State, 863 So.2d 271 (Fla. 2003) (standard for sufficiency of evidence review)
Crain v. State, 894 So.2d 59 (Fla. 2004) (conviction reversal warranted when not supported by competent, substantial evidence)