Wyatt v. State, 78 So. 3d 512

Wyatt murdered Cathy Nydegger in May 1988 after a crime spree stemming from North Carolina to Florida.
He and codefendant Lovette committed a Domino's Pizza murders in Vero Beach a few days earlier; they were tried separately.
At Nydegger's trial, the State linked Wyatt to the crime through stolen car evidence, a gun, bullets, and items matching the crane game; Nydegger's body was found with related items nearby.
Wyatt testified and claimed Lovette was with Nydegger; he admitted to being at Club 92 with Nydegger but asserted Lovette acted with Nydegger's knowledge.
During the penalty phase, the State introduced Wyatt's other violent acts; Wyatt presented lay witnesses about his troubled upbringing but no mental health expert; the jury imposed death barely 11-1.
Wyatt pursued postconviction relief under Fla. R. Crim. P. 3.850, including CJ claims about McCoombs, CBLA, and ineffective assistance, and sought habeas relief; the circuit court denied relief after multiple hearings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
McCoombs testimony and Brady/Giglio	Wyatt asserts newly discovered evidence shows McCoombs lied and prosecutors hid benefits.	Court found McCoombs credible; no suppression of favorable information shown; recantation letters immaterial.	No relief; credibility determinations supported; no Brady/Giglio violation shown.
CBLA new evidence and materiality	New FBI letter shows CBLA mischaracterized; could yield acquittal on retrial.	CBLA flaw not proven to be material; evidence already supported guilt beyond CBLA.	Denied relief; newly discovered CBLA evidence not likely to produce acquittal.
Ineffective assistance of counsel at penalty phase	Counsel failed to fully investigate social history and call Dr. Rifkin or mental health expert; mitigation was insufficiently developed.	Counsel's investigation and strategy were reasonable; presenting lay testimony was tactical and not deficient.	Denied relief; no deficient performance or prejudice shown.
Habeas appellate claims	Appellate counsel erred by not raising meritorious claims (e.g., prior markings, voir dire, interview rules).	Claims were procedurally barred or without merit; counsel reasonably omitted nonmeritorious issues.	Denied relief; appellate performance not shown to be deficient to prejudice.

Jones v. State, 709 So.2d 512 (Fla.1998) (two-pronged test for newly discovered evidence in postconviction relief)
Jones v. State, 591 So.2d 911 (Fla.1991) (original framework for evaluating newly discovered evidence and credibility)
Tompkins v. State, 994 So.2d 1072 (Fla.2008) (Giglio standard for false testimony and materiality)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-pronged deficient performance and prejudice standard)
Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (requirement of disclosure of favorable evidence)
Giglio v. United States, 405 U.S. 150 (U.S. 1972) (impeachment-influence of promised benefits on testimony)
Way v. State, 760 So.2d 903 (Fla.2000) (materiality standard for Brady evidence in Florida)
Occhicone v. State, 768 So.2d 1037 (Fla.2000) (reasonable mitigation investigation standard)
Rutherford v. Moore, 774 So.2d 637 (Fla.2000) (appellate counsel not ineffective for nonfrivolous omissions)