Date: Jun 2, 2026

Wyldes v. State: Postconviction “New Science” Challenges to Firearm Toolmark and Shoeprint Evidence Require Proof of a Probably Different Verdict

1. Introduction

In Donald Lee Wyldes, Jr. v. State of Iowa (Iowa May 29, 2026), the Iowa Supreme Court affirmed the denial of Wyldes’s third postconviction-relief (PCR) application arising from his 1987 convictions for first-degree murder (Ronald Starnes) and attempted murder (Ruby Starnes). Wyldes’s central theory was that “new scientific evidence” developed long after trial undermines the reliability of two forensic disciplines used against him: firearm toolmark comparison and footwear impression comparison.

The key issues were: (1) whether modern critiques and validation studies qualify as “evidence of material facts” under Iowa Code section 822.2(1)(d); (2) whether that new evidence probably would have changed the result of the 1987 trial, given Iowa’s standards for admissibility and the remaining circumstantial proof; (3) whether the disputed forensic testimony rose to a due process violation because it was “so inherently unreliable” as to make the trial fundamentally unfair; (4) whether Wyldes could satisfy Iowa’s demanding actual innocence standard; and (5) whether several additional claims were properly dismissed as untimely under Iowa Code section 822.3.

2. Summary of the Opinion

Firearm toolmark “new evidence” claim: The Court assumed modern toolmark studies constitute “new” evidence discovered after the verdict and not discoverable earlier, and it treated the evidence as material rather than merely cumulative or impeaching. But Wyldes failed the fourth Jones element—he did not show the new evidence probably would have changed the 1987 verdict. The Court further held firearm toolmark testimony remains admissible in Iowa.
Shoeprint “new evidence” claim: The original testimony was limited to a class-level “could have” opinion. Modern critiques about wear and time lag did not render that testimony inadmissible or outcome-changing—especially because Wyldes’s own PCR expert reached essentially the same class-characteristics conclusion.
Due process: The Court rejected the argument that the forensic evidence was “false, debunked, or discredited” in the constitutional sense. The record (including the Ames-II study) did not meet Iowa’s “inherently unreliable” threshold.
Actual innocence: Wyldes failed to prove, by clear and convincing evidence, that no reasonable factfinder could convict in light of all evidence (including the new evidence).
Timeliness/summary judgment: The Court affirmed dismissal of other claims as time-barred (Brady; ineffective assistance related to prior PCR counsel; subpoenas for other investigative files), emphasizing reasonable diligence and the limits of Allison after later statutory amendment and caselaw.

3. Analysis

3.1. Precedents Cited

A. Iowa PCR framework and the “new evidence” test

Davis v. State, ___ N.W.3d ___, ___, 2026 WL 1261001, at *1 (Iowa May 8, 2026): Cited for the basic function of PCR as distinct from direct appeal and for the proposition that PCR allows certain issues not raised (or not raisable) on direct review.
Jones v. State, 479 N.W.2d 265, 274 (Iowa 1991): Supplies the controlling four-part test for “newly discovered evidence” under Iowa Code section 822.2(1)(d), including the critical requirement that new evidence “probably would have changed the result of the trial.”
More v. State, 880 N.W.2d 487, 499–512 (Iowa 2016): Provides the Court’s modern template for “new science” litigation in PCR. Wyldes relies on More to treat significant scientific developments and “new statistical data previously unavailable” as potentially qualifying “new evidence,” while also emphasizing the “high” burden imposed by finality concerns. The Court also borrows More’s backward-looking approach: the question is how the original trial would likely have unfolded with the new information (including effects on admissibility and on the jury’s evaluation).

B. Admissibility standards for expert testimony (Iowa vs. Daubert jurisdictions)

Hutchison v. Am. Fam. Mut. Ins., 514 N.W.2d 882, 885 (Iowa 1994): Cited for Iowa’s “more liberal view” on expert admissibility.
Ranes v. Adams Lab'ys, Inc., 778 N.W.2d 677, 685–86 (Iowa 2010): Establishes Iowa’s simplified two-part inquiry under Iowa R. Evid. 5.702 (assistance to the trier of fact; expert qualification), and reiterates Iowa has not adopted a strict Daubert regime as a requirement.
Leaf v. Goodyear Tire & Rubber Co., 590 N.W.2d 525, 532 (Iowa 1999) (en banc): Recognizes that Daubert factors may be considered in certain cases, but not as an across-the-board mandate—supporting the Court’s refusal to import a stricter admissibility test to exclude toolmark testimony categorically.

C. Out-of-state and federal toolmark cases shaping the Court’s survey

United States v. Romero-Lobato, 379 F. Supp. 3d 1111 (D. Nev. 2019) and United States v. Pete, No. 3:22cr48, 2023 WL 4928523 (N.D. Fla. July 21, 2023): Both applied Daubert and still admitted firearm toolmark testimony, while noting concerns about objective standards. These cases support the Iowa Court’s conclusion that most courts continue to admit such evidence rather than impose categorical bans.
United States v. Williams, No. 19-CR-00282, 2025 WL 2444098 (N.D. Ill. Aug. 25, 2025) and United States v. Lang, No. 2:19-cr-150-SPC-NPM, 2025 WL 1921085 (M.D. Fla. July 11, 2025): Cited to show continued judicial confidence in low error rates and the availability of cross-examination and competing experts as safeguards.
Abruquah v. State, 296 A.3d 961, 971–1016 (Md. 2023): The principal restrictive counterpoint. The Iowa Court treats Abruquah as insightful but unpersuasive given (i) methodological disputes about error rates, especially how “inconclusive” calls are counted; and (ii) Maryland’s stricter “Daubert-Rochkind” approach versus Iowa’s more permissive expert-admissibility framework.
United States v. Brown, 973 F.3d 667, 704 (7th Cir. 2020); United States v. Richardson, No. 19-20076, 2024 WL 961228 (D. Kan. Mar. 6, 2024); and United States v. Graham, No. 4:23-cr-00006, 2024 WL 688256 (W.D. Va. Feb. 20, 2024): Used to show prevailing acceptance of toolmark identification “beyond the judicial system” and the trend of additional validation studies.

D. Footwear comparison precedent

United State v. Mahone, 328 F. Supp. 2d 77, 89 (D. Me. 2004) and United States v. Ross, 263 F.3d 844, 846–47 (8th Cir. 2001): Cited for the longstanding admission and general acceptance of footwear comparison testimony.

E. Due process standards for unreliable evidence

State v. Becker, 818 N.W.2d 135, 148 (Iowa 2012), overruled on other grounds by, Alcala v. Marriott Int'l, Inc., 880 N.W.2d 699 (Iowa 2016): Quoted (via More) for the general due process principle of “fundamental fairness.”
Manson v. Brathwaite, 432 U.S. 98, 117 (1977) and State v. Bruns, 304 N.W.2d 217, 219 (Iowa 1981): Provide the key threshold: evidence must be more than “merely untrustworthy”—it must be “so inherently unreliable” that allowing the jury to consider it denies due process.
United States v. Ausby, 916 F.3d 1089 (D.C. Cir. 2019) (per curiam); State v. Bridges, No. 90 CRS 23102-04, 2015 WL 12670468 (N.C. Super. Ct. Oct. 1, 2015); and Ex parte Henderson, 384 S.W.3d 833 (Tex. Crim. App. 2012) (per curiam): Cited as examples where materially false or debunked forensic science can violate due process—distinguished because Iowa found toolmark and shoeprint evidence not “totally false, debunked, or discredited.”

F. Actual innocence and standards of review

Lamasters v. State, 821 N.W.2d 856, 858–59 (Iowa 2012): Used to find error preserved when the district court initially failed to rule on actual innocence.
Dewberry v. State, 941 N.W.2d 1, 4 (Iowa 2019): Establishes de novo review of actual innocence claims.
Schmidt v. State, 909 N.W.2d 778, 797 (Iowa 2018): Supplies the substantive actual innocence standard (no reasonable factfinder could convict in light of all evidence) and the “clear and convincing evidence” burden.

G. Timeliness, Brady, summary judgment practice, and relation-back

Brady v. Maryland, 373 U.S. 83, 87 (1963) and State v. Barrett, 952 N.W.2d 308, 313 (Iowa 2020): Define Brady obligations and remedy principles; used to frame Wyldes’s suppressed-impeachment theory concerning the State’s toolmark expert’s experience.
Slaughter v. Des Moines Univ. Coll. of Osteopathic Med., 925 N.W.2d 793, 808 (Iowa 2019): Applied to require a resisting party to produce evidence (not mere allegations) to generate a genuine issue on summary judgment.
Allison v. State, 914 N.W.2d 866, 888–91 (Iowa 2018) and Goode v. State, 920 N.W.2d 520, 526–27 (Iowa 2018): Allison created a narrow relation-back pathway for certain successive PCR claims alleging ineffective assistance by PCR counsel; Goode limited it to the “exact same claim.” In Wyldes, even assuming Allison could apply, the claim fails because (i) this was a third PCR, not a second; and (ii) it was not filed promptly measured from the end of the first PCR proceeding.
Sandoval v. State, 975 N.W.2d 434, 436 (Iowa, 2022): Recognizes the 2019 statutory amendment superseding Allison by providing ineffective-assistance claims “shall not toll or extend” limitations nor relate back. The Court uses Sandoval to underscore the tightened statutory environment even though it resolves Wyldes’s argument on narrower grounds as well.

3.2. Legal Reasoning

A. The Court’s core doctrinal move: treating “new science” as potentially “new evidence,” but insisting on outcome probability

The Court followed More v. State in recognizing that major scientific developments and newly available statistical validation data can qualify as “evidence of material facts” under Iowa Code section 822.2(1)(d). Critically, the Court did not reject Wyldes at the gatekeeping stage; it accepted that modern toolmark studies arose after the verdict and could not have been discovered with due diligence in 1987. It also concluded the evidence was not merely “cumulative or impeaching,” because trial counsel did not present a methodology-level validity attack (indeed, Wyldes’s own toolmark expert largely endorsed the discipline and even agreed the crime-scene and road casings were fired from the same firearm).

The decision turns on element (4) of Jones v. State: whether the new evidence probably would have changed the result. The Court characterizes this as a “high” standard tied to finality, and it reiterates (per More) that the inquiry is not harmless error, but a fact-intensive counterfactual about the trial’s likely outcome if the new evidence had been available then.

B. Firearm toolmark evidence: admissibility plus “residual case” analysis

On toolmark evidence, the Court addressed two linked questions: (1) would the evidence remain admissible in Iowa; and (2) even with altered testimony, would the overall case likely produce the same verdict?

Admissibility in Iowa: The Court emphasized Iowa’s comparatively “low bar” for expert testimony under Ranes v. Adams Lab'ys, Inc. and Hutchison v. Am. Fam. Mut. Ins.. It declined to follow Abruquah v. State largely because Maryland applies a more stringent “Daubert-Rochkind” reliability regime, while Iowa has never adopted Daubert as mandatory and uses a simpler assistance/qualification framework. In that context, and after surveying post-PCAST cases, the Court aligned with the “majority of courts” continuing to admit firearm toolmark evidence.
What changes at trial would the “new science” likely produce? The Court accepted that the strongest use of the new material would be to attack an examiner’s claim of “absolute certainty” when the source firearm is not available, and to challenge the subjectivity of AFTE’s “sufficient agreement” standard and the handling of “inconclusive” outcomes in error-rate discussions. Even so, the Court concluded a jury would not deem the whole method “wholly unreliable,” particularly given the Court’s reading of Ames-II as demonstrating low error rates “within statistically acceptable margins,” plus repeatability and reproducibility “that similarly suggest the method’s reliability.”
Outcome probability: The Court held the verdict would probably stand because (i) key portions of the toolmark testimony would remain (at minimum, class-level conclusions and non-exclusion/consistency conclusions), (ii) the “progressive deterioration” dispute already existed at trial and the jury sided with the State, and (iii) substantial nonforensic evidence independently supported guilt (contradicted alibi; shifting statements about firearm ownership; testimony that Wyldes possessed the Marlin before and after the murder; familiarity with the home; matching the victim’s description; and ammunition/casing circumstances consistent with the crime scene).

C. Shoeprint testimony: limited claim, limited consequence

The Court treated footwear comparison as a generally accepted forensic practice, but it did not rest on acceptance alone. It focused on how modest the original testimony was: the expert said Wyldes’s shoes could have made the prints, while acknowledging other shoes of the same type, size, and tread design exist. Because the trial evidence was framed as class-level association rather than a definitive identification, modern criticisms about outsole wear and the four-month delay did not amount to a methodological demolition. The Court found it significant that Wyldes’s own PCR expert likewise found “an association of class characteristics.”

D. Due process: “inherently unreliable” is a narrow lane

Wyldes attempted to constitutionalize the evidentiary disputes by invoking due process. The Court applied the stringent standard articulated in State v. Bruns and reiterated in More v. State: the question is not whether evidence is debatable or “merely untrustworthy,” but whether it is “so inherently unreliable” that submitting it to the jury is itself fundamentally unfair.

The Court acknowledged cases like United States v. Ausby, State v. Bridges, and Ex parte Henderson, where later debunking of forensic science supported relief. But it distinguished them on the facts: in this record, firearm toolmark and shoeprint testimony were not “totally false, debunked, or discredited,” especially given the Court’s understanding of Ames-II results and the restrained nature of the shoeprint opinion.

E. Actual innocence: a higher bar than “probably different result”

Because the Court already held the new evidence would not probably change the verdict, it reasoned Wyldes necessarily could not satisfy the even higher Schmidt v. State standard for actual innocence (no reasonable factfinder could convict) proven by clear and convincing evidence. The Court emphasized the cumulative strength of circumstantial evidence and the continued admissibility of at least some toolmark testimony.

F. Timeliness rulings: diligence and the narrowing of relation-back

Brady claim: The Court affirmed dismissal because Wyldes did not show the evidence could not have been discovered with reasonable diligence within the limitations period; he relied on an unsupported assertion of late discovery, insufficient under summary-judgment standards (citing Slaughter v. Des Moines Univ. Coll. of Osteopathic Med. and Iowa R. Civ. P. 1.981(5)).
Ineffective assistance of prior PCR counsel: The Court rejected reliance on Allison v. State for multiple reasons: (i) Allison concerned a second PCR, not a third; (ii) even if extended, Wyldes failed the “promptness” requirement measured from the end of the first PCR proceeding; and (iii) the Court noted the 2019 legislative amendment to section 822.3 (recognized in Sandoval v. State) that superseded Allison’s relation-back approach in any event.
Subpoenas for investigative files: The Court affirmed the quash order because Wyldes could not articulate a clear connection to his case and because alternative-suspect theories were not “new”— they could have been pursued long ago, outside the exception to section 822.3.

3.3. Impact

PCR “new science” claims remain possible but outcome-driven: The opinion reinforces that modern validation studies and scientific critiques can satisfy the “new” and “due diligence” prongs, and may even be “material,” but relief will typically hinge on the demanding Jones prong (4): whether the new evidence would probably change the verdict. This anchors Iowa PCR practice in an outcome-probability framework rather than a discipline-validity referendum.
Toolmark testimony remains admissible in Iowa absent extraordinary showings: By aligning with the “majority of courts” and emphasizing Iowa’s liberal expert admissibility standard, the Court signals that categorical exclusion arguments—especially those borrowing from more stringent jurisdictions like Maryland in Abruquah v. State—face a steep climb in Iowa.
Constitutional due process is not an all-purpose “bad forensics” remedy: The Court’s adherence to the Bruns “inherently unreliable” standard limits due process relief to situations involving truly debunked/false science, not merely contested or probabilistic expert methods.
Limits on late Brady and IAC theories in successive PCR litigation: The decision underscores diligence burdens for Brady claims based on public records and highlights the narrow (and now largely statutory-superseded) corridor for relation-back under Allison v. State, particularly for third or later PCR applications and long delays.

4. Complex Concepts Simplified

Postconviction relief (PCR): A civil procedure that allows a convicted person to challenge a conviction after the direct appeal ends, typically raising claims like newly discovered evidence, constitutional violations, or ineffective assistance.
“Newly discovered evidence” under Iowa Code § 822.2(1)(d): Under Jones v. State, the applicant must prove: (1) discovery after the verdict; (2) not discoverable earlier with due diligence; (3) material and not merely cumulative/impeaching; and (4) it probably would have changed the verdict.
Firearm toolmark examination: A comparison of microscopic marks on bullets or cartridge cases to infer whether they were fired from the same firearm. Critics argue key steps depend on subjective judgments and assumptions about uniqueness.
Class, subclass, and individual characteristics: Class traits are common to a model/design; subclass traits may be shared among a manufacturing batch; individual traits are asserted to be unique to one firearm. Wyldes’s PCR expert argued the discipline cannot reliably distinguish subclass from individual traits without far broader manufacturing-line data.
“Inconclusive” results and error rates (Ames-II dispute): In toolmark studies, “inconclusive” means the examiner declines to call an identification or elimination. Counting inconclusives as “errors” yields much higher apparent error rates; excluding them yields lower “wrong-call” rates. Wyldes
Repeatability vs. reproducibility: Repeatability: the same examiner reaches the same conclusion when retesting. Reproducibility: different examiners reach the same conclusion on the same evidence.
Due process “fundamental unfairness” from unreliable evidence: Under State v. Bruns, evidence must be “so inherently unreliable” that letting the jury consider it denies due process—not merely disputed or imperfect.
Actual innocence: Under Schmidt v. State, the applicant must prove by clear and convincing evidence that no reasonable factfinder could convict in light of all evidence, including the new evidence.
Brady violation: Under Brady v. Maryland, the prosecution violates due process by suppressing material evidence favorable to the accused. In Iowa PCR practice, a claimant must also overcome timeliness rules by showing the claim could not have been raised earlier with reasonable diligence.

5. Conclusion

Wyldes clarifies that Iowa courts will treat substantial scientific developments—especially modern validation data—as potentially qualifying “new evidence” in PCR. But the decision also reinforces two powerful limiting principles: (1) Iowa’s comparatively liberal expert-admissibility framework makes categorical exclusion of longstanding forensic disciplines unlikely absent extraordinary proof, and (2) the dispositive question for a new-trial remedy remains whether the new evidence would probably have changed the verdict, assessed against the entire trial record. By pairing continued admissibility of firearm toolmark and restrained shoeprint testimony with robust circumstantial evidence, the Court found no basis for a new trial, no due process violation, and no actual innocence, while also tightening the practical feasibility of late-raised ancillary claims through timeliness and diligence requirements.