Wyatt v. State
71 So. 3d 86
| Fla. | 2011Background
- Wyatt and codefendant Lovette committed a May 1988 triple murder at a Vero Beach Domino's; Wyatt was later convicted of three counts of first-degree murder and sentenced to death.
- Evidence at trial included eyewitness testimony, DNA, vehicle and weapon connections, and handwriting matches linking Wyatt to the crimes.
- Wyatt waived presenting mitigation at the penalty phase, despite prior requests to call witnesses; the court conducted a brief penalty phase and imposed death sentences.
- Wyatt pursued postconviction relief under Florida Rule of Criminal Procedure 3.850, raising numerous claims including CBLA reliability and new witness allegations.
- A FBI CBLA letter in 2008 acknowledged that Riley’s trial testimony extended beyond the limits of CBLA, leading to additional evidentiary hearings on CBLA and McCoombs’ trial testimony.
- The postconviction court denied relief on Wyatt’s final claims; Wyatt separately sought habeas relief challenging various constitutional and procedural aspects of the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 2008 FBI CBLA letter constitutes newly discovered evidence | Wyatt contends the letter is new and could yield acquittal on retrial. | State argues the letter is not applicable or does not meet two-prong test. | Letter is newly discovered evidence; however it would not probably produce acquittal on retrial. |
| Whether CBLA evidence violated Brady/Giglio | Wyatt asserts suppression and false testimony affected outcome. | State claims no suppressed material and no proven false testimony known to prosecutors. | No Brady/Giglio violation; no proof of prosecutorial knowledge of false testimony or suppression. |
| Whether counsel was ineffective for challenging CBLA or failing to investigate its basis | Wyatt claims counsel failed to adequately challenge CBLA or obtain brain/mind evidence. | Defense relied on experts; no deficient performance established. | No Strickland deficiency; counsel reasonably relied on expert evaluations available at the time. |
| Whether newly discovered evidence about McCoombs fabricating testimony warrants relief | Wyatt seeks retrial/impeachment evidence based on new allegations. | Record credibility supported the trial witnesses; alleged fabrication lacks probative value for retrial. | No basis for relief; credibility determinations supported denial. |
| Whether there was ineffective assistance in penalty-phase waiver and mitigation investigation | Wyatt argues waiver of mitigation was invalid without thorough investigation. | Counsel conducted reasonable investigation; waiver was knowingly and voluntarily made. | waiver valid; no ineffective assistance established. |
Key Cases Cited
- Jones v. State (Jones II), 709 So.2d 521 (Fla. 1999) (defines two-prong test for newly discovered evidence)
- Jones v. State (Jones I), 591 So.2d 911 (Fla. 1991) (first prong: unknown at trial by party or counsel must be; diligence required)
- Kearse v. State, 969 So.2d 976 (Fla. 2007) (discussed timing/exists-at-time-of-trial language; guidance overruled)
- Preston v. State, 970 So.2d 789 (Fla. 2007) (new DNA testing as newly discovered evidence example)
- Hildwin v. State, 951 So.2d 784 (Fla. 2006) (new DNA testing and exception to rule for newly discovered evidence)
- Reese v. State, 14 So.3d 913 (Fla. 2009) (limits on reliance of expert testimony and method-accuracy concerns)
- Stewart v. State, 37 So.3d 243 (Fla. 2010) (neuropsychological/effect of mitigation investigations; standards for counsel performance)
- Pearce, 994 So.2d 1094 (Fla. 2008) (waiver of mitigation and obligation to investigate)
- Mungin v. State, 932 So.2d 986 (Fla. 2006) (evidence of suppression and standards for evaluating Brady claims)