Wyatt v. State

906 S.E.2d 380, 319 Ga. 658
CourtSupreme Court of Georgia
DecidedSeptember 4, 2024
DocketS24A0487
StatusPublished
Cited by1 cases

This text of 906 S.E.2d 380 (Wyatt v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wyatt v. State, 906 S.E.2d 380, 319 Ga. 658 (Ga. 2024).

Opinion

319 Ga. 658 FINAL COPY

S24A0487. WYATT v. THE STATE.

LAGRUA, Justice.

Appellant Donte Wyatt was convicted of malice murder and

related crimes in connection with the April 2015 strangulation death

of Catherine Montoya.1 In his sole enumeration of error, Wyatt

1 The crimes occurred on April 13, 2015. On June 16, 2016, a DeKalb

County grand jury indicted Wyatt for malice murder (Count 1), felony murder (Count 2), three counts of aggravated assault (Counts 3, 6, and 7), aggravated sodomy (Count 4), rape (Count 5), home invasion (Count 8), burglary in the first degree (Count 9), false imprisonment (Count 10), theft by taking (Count 11), and criminal trespass (Count 12). Wyatt was tried in October 2016, and the jury found him guilty of all counts. He was sentenced to serve life in prison without the possibility of parole for malice murder (Count 1), a consecutive sentence of life in prison with the possibility of parole for aggravated sodomy (Count 4), a consecutive sentence of life in prison without the possibility of parole for rape (Count 5), 20 concurrent years in prison for aggravated assault (Counts 6 and 7), a consecutive sentence of life in prison with the possibility of parole for home invasion (Count 8), ten consecutive years in prison for false imprisonment (Count 10), ten consecutive years in prison for theft by taking (Count 11), and 12 consecutive months in prison for criminal trespass (Count 12). All other counts were merged or vacated by operation of law. In total, Wyatt received three life sentences without the possibility of parole and one life sentence with the possibility of parole, plus 20 years to serve in prison and an additional 12 months to serve. Wyatt filed a timely motion for new trial, which was amended through new counsel. After holding an evidentiary hearing, the trial court denied the motion for new trial on September 1, 2023. Wyatt filed a timely notice of appeal, and the case was docketed to the Court’s April 2024 term and submitted for a decision on the briefs. contends that the trial court erred in admitting evidence that he

attacked his ex-wife in the hours prior to killing Montoya because

the probative value of such evidence was substantially outweighed

by the danger of unfair prejudice in violation of OCGA § 24-4-403.

We affirm for the reasons set out below.

The evidence presented at trial established that Wyatt was

married to Heather Duffy from 2004 until February 2015, at which

time Duffy moved into another home with the couple’s two children.

Duffy testified that, on April 11, 2015, she took the children on a

one-night trip to Tennessee, during which she received multiple

calls and text messages from Wyatt and received a notification that

her home security alarm had been triggered. Around 8:15 a.m. on

April 13, 2015, Duffy received a text message from Wyatt containing

a picture of her car keys, for which she had been searching. Wyatt

claimed he found the car keys in his pants pocket. Wyatt and Duffy

arranged to meet at a diner in Henry County to exchange the car

keys. At the time of this meeting, Wyatt was driving a white

Chevrolet Silverado pick-up truck that Duffy had rented for him.

2 Upon meeting, Wyatt requested a hug from Duffy and for her to eat

breakfast with him before he returned the keys. Duffy reluctantly

agreed. Once they sat at a table, Wyatt accused Duffy of keeping

their children away from him. Duffy told Wyatt that she “[was]n’t

going to discuss that,” and Wyatt left the table and exited the diner.

Duffy watched Wyatt enter the rental truck, which was parked in

the diner’s parking lot, and just “sit[ ] there.” Duffy approached the

truck to ask Wyatt for her keys. Wyatt responded by asking Duffy

for another hug. Duffy told him that she “ain’t got time for all this

hugging” and began walking to her car, which was parked near the

truck. Wyatt stepped out of the truck and followed Duffy.

As Duffy entered her vehicle, Wyatt stood by the car so that

she was unable to close the door and asked Duffy what their children

“would do if they d[idn’t] have [him] or they d[idn’t] have [her],”

which Duffy took as a threat. Duffy told Wyatt to move so that she

could drive away. In response, Wyatt “put his head down” and told

her that “he was . . . sorry it got to go this way, but this the way it’s

going to go,” and proceeded to stab her with something in the leg.

3 Wyatt then told her that he was planning to “stab [her] eight times

in [her] face” and was “fixing to kill [her].” Wyatt asked Duffy for the

keys to her car and stabbed Duffy “again in [her] thigh.” Duffy then

moved over to the passenger seat and Wyatt entered the car, sitting

in the driver’s seat. Wyatt “lifted his shirt up, and . . . pulled some

[zip-]ties out and duct tape out from underneath his shirt” and told

Duffy to “put [her] hands in [the] ties.” Duffy then told Wyatt that

she had dropped the car keys outside, and Wyatt told her to stay in

the vehicle while he looked, warning her that “if [she] tr[ied] to run”

he was “going to kill [her] right here in this van.” Wyatt exited the

car and Duffy “jumped out,” yelling at a man who was exiting the

diner to “please help [her]” because Wyatt was “trying to kill [her].”

Wyatt then ran over to Duffy and stabbed her with a knife in the

back, which Duffy was able to remove. The man told Duffy to “just

run” and called 911. Duffy ran toward a nearby gas station and

jumped into a parked car. Wyatt then drove off in the rental truck.

Duffy testified that Wyatt stabbed her a total of four times.

The responding Henry County officers arrived on the scene

4 around 9:00 a.m. Duffy informed one of the officers that Wyatt had

stabbed her and was driving the rental truck. The officer contacted

the rental company, which disabled the truck and informed the

officer of the truck’s location in DeKalb County.

DeKalb County officers were dispatched to the truck’s location,

which happened to be right outside of Montoya’s house,2 and arrived

on the scene around 11:30 a.m. One officer testified that, while the

officers were maintaining a perimeter around the vehicle, he saw a

man matching Wyatt’s description walk out of the house, attempt to

start the truck, then walk back inside the house. A few minutes

later, the officer observed a maroon Kia Sorento — later identified

as Montoya’s vehicle — back out of the driveway. A second officer

followed the Kia in his own vehicle and, after observing the Kia drive

through a stop sign, turned on his lights. The Kia then sped down

the street and crashed near a ravine. Upon approaching the vehicle,

officers discovered that it was empty, and multiple K-9 officers

followed Wyatt’s scent with their dogs through the woods to another

2 There was no apparent connection between Wyatt and Montoya.

5 nearby house.3 The DeKalb County SWAT Team was dispatched to

this other house and informed that the suspect “was wanted for a

separate crime in Henry County that involved a knife” and “had fled

into one house, later came out of the house and fled again in a vehicle

and broke into another home.” The SWAT Team arrested Wyatt,

and, at the time of his arrest, Wyatt was in possession of a Kia car

key. Investigators also discovered a knife in the basement of the

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Related

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Bluebook (online)
906 S.E.2d 380, 319 Ga. 658, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wyatt-v-state-ga-2024.