Wyatt v. State; Wyatt v. Buss
Annotate this CaseDefendant appealed the denial of his amended and supplemental motions for postconviction relief and petitioned for writ of habeas corpus where he was convicted of first degree murders and sentenced to death for the commission of a triple homicide. Defendant raised numerous claims before the court on appeal but focused primarily on two of those claims: whether the state presented expert testimony on comparative bullet lead analysis (CBLA), which evidence had now established was no longer a reliable science, and whether newly discovered evidence showed that a critical state witness testified untruthfully. The court held that the 2008 letter at issue clearly qualified as newly discovered evidence; thus, the postconviction court erred in finding that the claim was procedurally barred and that the letter did not constitute newly discovered evidence. Regardless of these errors, the court affirmed the postconviction court's denial of relief because defendant could not demonstrate that consideration of the letter would probably produce an acquittal on retrial under the newly discovered evidence standard. The court also held that, as to the Brady v. Maryland and Giglio v. United States claims, there was no basis for concluding that the state withheld favorable evidence under Brady or knowingly presented evidence at the original trial under Giglio. After the FBI discovered the errors in the original CBLA evidence introduced at trial, defendant was made aware of these errors by letter. The court rejected defendant's ineffectiveness claim because the record showed that trial counsel retained an independent expert to evaluate the FBI's CBLA and the expert provided counsel with no basis to challenge that analysis. Therefore, the court affirmed the postconviction court's denial of relief and also denied defendant's habeas petition.
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