Donte Wyatt Convicted of Strangulation Murder; Court Upholds Evidence of Prior Attack in Insanity Defense Rebuttal
Donte Wyatt has been convicted of malice murder and related crimes in the strangulation death of 30-year-old Catherine Montoya. The ruling follows Wyatt’s appeal challenging the admission of evidence from a prior violent incident involving his ex-wife, Heather Duffy. The Georgia Supreme Court upheld the trial court’s decision, affirming that the evidence was relevant to counter Wyatt’s insanity defense.
The violent events unfolded on April 13, 2015, when Wyatt lured Duffy to a diner in Henry County shortly after 8:15 AM. Upon her arrival, Wyatt attacked Duffy, stabbing her four times. Following the attack, he fled the scene, which ultimately led law enforcement to track his rented vehicle to Montoya’s residence in DeKalb County. At approximately 11:30 AM, officers spotted Wyatt leaving Montoya’s house in her vehicle. Upon entering the residence, they discovered Montoya had been strangled to death.
During the trial, Wyatt’s defense claimed insanity, arguing that his mental state at the time of the attacks should absolve him of responsibility. He conceded that the Duffy attack was admissible as evidence but contended that the details of the incident in Henry County were prejudicial and had little relevance to the charges related to Montoya’s murder.
However, the court disagreed, asserting that the evidence from the Henry County incident was crucial in demonstrating Wyatt’s mental state at the time of Montoya’s murder. It established that Wyatt was aware of the wrongfulness of his actions, as evidenced by his behavior during the preceding attack on Duffy. Before stabbing Duffy, he expressed remorse, stating he was “sorry it got to go this way.” Furthermore, the court noted that after the attack on Duffy, Wyatt’s actions mirrored those taken after Montoya’s murder; he fled to avoid capture, indicating a consciousness of guilt.
The court detailed how the evidence also illustrated Wyatt’s ability to plan and deliberate, as he had brought items such as a knife, duct tape, and zip ties to the diner, suggesting premeditation. Witnesses testified that Wyatt appeared calm and normal prior to attacking Duffy, reinforcing the argument that he was in control of his actions throughout both incidents.
In reviewing the case, the court highlighted that the trial judge took necessary precautions to minimize any potential bias against Wyatt by instructing the jury to focus solely on the crimes charged against Montoya. The indictment was presented clearly, with the jury provided written copies to ensure they understood the specific charges.
Ultimately, the court found no abuse of discretion in the trial court’s admission of the Henry County incident evidence. The ruling emphasizes the importance of establishing a defendant’s mental state and awareness during the commission of violent crimes, particularly in cases involving claims of insanity.
