Background
On October 15, 1986, Ronald Starnes was shot eight times and killed outside his rural Wayne County, Iowa farmhouse. His wife Ruby survived an attempted entry by the masked gunman after bracing herself against the door while shots were fired. Police found no fingerprints but recovered ten spent .22 caliber shell casings, a partial shoe print, and evidence of deliberate preparation—cut phone lines and slashed tires. Donald Lee Wyldes Jr. came under suspicion after witnesses placed him near the farmhouse days before the murder and contradicted his alibi. His story changed repeatedly across police interviews, and witnesses reported seeing him with a Marlin-brand .22 caliber rifle both before and after the killing.
At trial in 1987, the State’s firearm toolmark examiner, Robert Harvey, testified that all ten casings recovered at the farmhouse and on a nearby gravel road were fired from the same rifle, and presented a “progressive deterioration” theory tying those casings to Wyldes’s Marlin. Even Wyldes’s own expert agreed the casings from both locations came from the same firearm. A footwear analyst testified that shoe prints found at the scene were consistent with Wyldes’s shoes. The jury convicted Wyldes of first-degree murder and attempted murder; he received a life sentence without parole plus twenty-five years.
After his direct appeal failed in 1989 and two prior postconviction-relief applications were denied, Wyldes filed a third application in 2010, amended in 2020. He argued that modern scientific studies—including the 2020 Ames National Laboratory (Ames-II) validation study and criticism from the President’s Council of Advisors on Science and Technology—had exposed firearm toolmark and shoe print analysis as fundamentally unreliable, constituting newly discovered evidence warranting a new trial under Iowa Code § 822.2(1)(d). The district court denied relief after a hearing, and Wyldes appealed.
The Court’s Holding
The Iowa Supreme Court unanimously affirmed the denial of postconviction relief. Writing for the court, Justice McDermott applied the four-part test for newly discovered evidence from Jones v. State, 479 N.W.2d 265 (Iowa 1991): the evidence must have been discovered after the verdict, not discoverable earlier with due diligence, material and non-cumulative, and likely to have changed the trial’s result. The court agreed Wyldes satisfied the first three elements—post-trial studies were unavailable at the time, and unlike his trial expert (who endorsed toolmark methodology while disputing specific findings), the new evidence mounted a foundational challenge never presented to the jury.
The court denied relief on the fourth and dispositive element, finding that the new evidence would not probably have changed the trial’s outcome. Reviewing the Ames-II data and a broad survey of post-PCAST case law, the court concluded that firearm toolmark analysis continues to show low error rates within statistically acceptable margins and retains general acceptance among examiners and most courts. The court acknowledged sharp disagreement over how to count “inconclusive” responses in proficiency studies—treated as errors, they inflate apparent error rates to over 25%; excluded, they drop below 2%—but declined to resolve that debate, noting the weight of judicial authority still permits such testimony.
The court noted that a minority of jurisdictions, exemplified by the Maryland Supreme Court’s decision in Abruquah v. State, 296 A.3d 961 (Md. 2023), now bar unqualified same-source conclusions. But the Iowa court aligned itself with the majority view—reflected in decisions from federal courts in Nevada, Florida, Illinois, Virginia, and Kansas—that concerns about subjectivity and inconclusive rates go to weight rather than admissibility and can be addressed through cross-examination and competing experts. Because Harvey’s testimony would likely have remained admissible in a hypothetical retrial, and given the substantial non-forensic evidence against Wyldes (contradicted alibi, shifting statements, witness accounts of the Marlin rifle), the court held the new evidence would not probably have changed the verdict.
Key Takeaways
- Iowa adopts the majority rule: modern scientific critiques of firearm toolmark analysis, including post-PCAST studies, do not render such testimony inadmissible; concerns go to weight and are addressable through adversarial testing.
- A postconviction-relief applicant challenging forensic methodology as newly discovered evidence must clear a high bar on the fourth Jones element—that the evidence “probably would have changed the result”—which requires a fact-intensive, case-specific backward-looking analysis of the entire trial record, not just the challenged expert evidence.
- The court left open the debate over how “inconclusive” proficiency-study results should be counted, but found the question immaterial where the overall record, including strong non-forensic evidence, independently supported the verdict.
- Where a trial-era defense expert embraced the methodology at issue and only disputed specific findings, subsequent evidence attacking the methodology itself is non-cumulative and satisfies the materiality element—but must still surmount the probable-change-in-result hurdle.
Why It Matters
Wyldes arrives at a moment of active national litigation over the admissibility of pattern-matching forensic disciplines—toolmarks, shoe prints, bite marks—following the 2016 PCAST report. The Iowa Supreme Court’s decision aligns the state with the federal majority that continues to admit such testimony while acknowledging methodological limitations, and against the more restrictive Maryland approach in Abruquah. For practitioners, the opinion clarifies that Iowa’s postconviction-relief framework will not easily convert scientific controversy, even well-documented controversy, into a ticket to retrial when the underlying forensic category retains broad acceptance and the broader evidentiary record is strong.
The decision also offers a roadmap for the “probably would have changed the result” analysis in forensic-challenge PCR cases: courts should assess both whether the challenged testimony would still have been admitted under updated standards and whether, even if excluded or qualified, the remaining evidence would independently sustain the verdict. Defense practitioners seeking relief on forensic grounds will need to show not just that science has moved, but that the shift is decisive enough to overcome an otherwise robust trial record.