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Jeremy Puckett

Other Sacramento County, California exonerations
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On March 14, 1998, the body of 19-year-old Anthony Galati was found along the side of White Rock Road in Rancho Cordova, California, a suburb east of Sacramento. He had been shot twice in the back of the head. Two days later, his Pontiac Firebird was found set ablaze at an apartment building parking lot.

The crime went unsolved until October 1999 when Israel Sept, an inmate in a California prison for unlawful discharge of a firearm, told police that he was present when Galati was killed. Claiming that he had converted to Christianity and wanted to set his life straight, Sept said that on the night of his death, Galati was looking to buy drugs. Sept said that 23-year-old Jeremy Puckett pistol-whipped Galati, robbed him, and killed him with the help of 18-year-old Angela Dvorsky.

According to Sept, he was dealing drugs at the apartment of William Van Hill when Galati came looking to buy drugs. Sept said he left the room and when he came back, Puckett and Dvorsky had tied up Galati and Puckett pistol-whipped him. They then put Galati in the back seat of his car and Dvorsky sat on him. Sept said he surreptitiously told Galati he was going along with them to protect him and got into the passenger seat. Puckett drove the car to White Rock Road, where he and Dvorsky took Galati out of the car. Puckett shot Galati and they drove off, Sept said.

In June 2000, based on his statement, Sept was charged with murder and robbery. He went to trial in Sacramento County Superior Court on March 28, 2001. After a jury was selected and opening statements were made, Sept, who was facing a possible sentence of life in prison without parole, agreed to plead guilty to charges of robbery and accessory to murder. In return for testifying against Puckett, Sept would be sentenced to 11 years and eight months in prison.

Shortly thereafter, Puckett was charged with first-degree murder, robbery, and unlawful use of a firearm. Prior to trial, Puckett’s lawyer and an investigator interviewed Sept on three occasions. During one meeting, Sept recanted his original statement.

Sept said that he sold drugs out of an apartment where Van Hill and Larry Middlebrooks were staying. In return for being allowed to sell drugs, Sept said, he provided money or drugs to Van Hill. Sept said that Middlebrooks, along with Dvorsky and her boyfriend, James “Jaymo” Reeves, set up Galati to be robbed.

“Jeremy was not involved,” Sept said. “Jeremy knew nothing about robbing anyone.”

Sept said that when Galati showed up, “I thought he was a cop. The dude didn’t look like a drug user. What was this white dude who wasn’t all smoked out coming up to the apartment for?”

He said, “I remember that night that Middlebrooks called Jaymo and Angela to rob that dude.” Sept said, “I never saw Jeremy rob anyone that night. I never saw Jeremy take any money from anyone that night. That’s the God’s truth.”

Subsequently, however, Sept recanted his recantation and then later reaffirmed the recantation—all before Puckett’s trial.

In January 2002, Puckett went to trial in Sacramento County Superior Court. By that time, Dvorsky was dead. She had been stabbed and dumped in the American River near Sacramento. Her body had been recovered on May 1, 1998, about six weeks after Galati was murdered. During the prosecution’s opening statement to the jury, the prosecutor said that Sept, when he came forward, wanted his “family protected” in return for implicating Puckett. He noted that everyone who was present on the night of Galati’s death would testify—except for Dvorsky, who had been killed.

Out of the presence of the jury, Puckett’s lawyer asked for a mistrial because there was no evidence connecting Puckett to Dvorsky’s murder. The prosecutor told the judge that there was evidence linking Puckett to the murder, just not enough to charge him. Even so, the judge denied the motion for mistrial, and instead, instructed the jury that no evidence would show Puckett murdered Dvorsky and threatened Sept.

The medical examiner testified that the time of death was between 5 a.m. and 7 a.m. on Saturday, March 14, 1998—about eight to 10 hours before Galati’s body was found.

Sept testified that he was at a convenience store when he ran into Middlebrooks and Galati. The three of them drove in Galati’s car to the apartment where Van Hill and Middlebrooks were staying. Later that evening, Dvorsky arrived with Jaymo, who walked into the bathroom, talked to Middlebrooks, and then left. Puckett then came over, Sept said.

Sept said he needed to sell drugs to pay an overdue utility bill. Because he thought Galati might be a police officer, he offered to sell to Middlebrooks, who then offered to buy the drugs with money from Galati. But because Galati only had a $100 bill, Middlebrooks and Galati left to find change. Ultimately, he said, after leaving, coming back, and leaving again, they returned around 1 a.m. with change.

Sept said Middlebrooks bought $10 worth of crack cocaine from him. He then went into the bathroom to smoke it with a woman who had come to the apartment, Patty Scott-Bostic. Sept testified he sat in the living room drinking beer with Puckett, Galati, and Dvorsky, who was sitting on Galati’s lap, making him “all excited.” After a bit, Galati went into the bathroom and when he came out, he told Sept that Middlebrooks wanted to see him.

Sept said he sold Middlebrooks another $5 worth of crack. When he returned to the living room about 10 minutes later, Galati was on the floor and Puckett was standing over him holding a gun. He said Puckett said he was “about to kill everyone in the apartment.”

Sept said that he went into the bathroom and warned Middlebrooks and Scott-Bostic to stay there. As Sept emerged, Van Hill came out of his bedroom and Sept told him to stay in his room.

When he returned to the living room, Sept said Dvorsky was sitting on Galati’s back, tying him up with electrical cords. When she finished, Puckett said, “Come on, let’s go.” Sept said he and Puckett lifted Galati off the floor. As they took him outside, Sept said he quietly told Galati he was going to try to make sure nothing happened to him. They put Galati in the back of the car and began driving. Sept said he begged Puckett to let Galati go, but Puckett refused.

Along a rural section of White Rock Road in Rancho Cordova, as Sept told it, Puckett pulled over and with Dvorsky’s help, pulled Galati from the back seat. Puckett then shot him twice.

Sept said they then drove to a nearby motel, where Puckett made him rent a room. The prosecutor showed Sept an exhibit consisting of five pages of receipts and invoices from the motel. “And you signed Israel Sept for March the, it looks like 13th to 14th, I think, is that right?” the prosecutor asked. Sept said that was correct, agreeing that the room was booked on Friday, March 13 with check out on Saturday, March 14.

Sept said he walked home and Puckett and Dvorsky stayed in the room.

During cross-examination, Sept admitted to inconsistencies between his testimony and his pre-trial statements to the police. For example, he had told sheriff’s deputies that Galati was pistol-whipped, but at trial he said he never saw any pistol-whipping. The prosecution had noted during its opening statement that blood was found in the living room.

Sept admitted that his statements to investigators that Puckett threatened him were false and only made to engender sympathy. During his trial testimony, Sept said he got out of the car when it stopped on White Rock Road, but he had told detectives that he stayed in the car.

Puckett’s defense lawyer established that Sept held a grudge against Puckett because Sept held him responsible for a friend’s death. However, the trial judge refused to allow the defense to go into the circumstances—Sept’s friend died in a fire and Puckett managed to rescue everyone but the friend. As a result, the implication was that Sept held Puckett responsible for yet another death.

The defense lawyer asked Sept if he had told him and the defense investigator that Puckett had nothing to do with the crime and that Jaymo, Dvorsky and Middlebrooks set up the robbery.

Although Sept denied ever saying that, the defense attorney failed to bring up Sept’s recantation. He not only failed to question Sept about the statement, but also failed to call the investigator as a witness to testify about the recantation and impeach Sept’s testimony.

Van Hill testified that about five minutes after he went back to his bedroom at Sept’s command, he heard whimpering and came out again. He said he saw Dvorsky and Galati on the floor. A man he identified by his height as Puckett was standing over them demanding Galati’s money and car keys. Van Hill said he did not see the front or side of the man’s face. He said that he saw Sept and that Puckett was substantially taller than Sept, who he said was about 5 feet 4 inches to 5 feet 5 inches tall. Actually, however, Sept was 5 feet 10 inches tall and Puckett was 6 feet 1 inch tall.

During cross-examination, Van Hill said for the first time that he recognized Puckett’s voice. He said his memory had gotten better since he was first interviewed three years earlier.

The defense lawyer failed to confront Van Hill with his previous statements to police during which he said everyone in the apartment that night was about the same height.

Middlebrooks also testified for the prosecution, but contradicted Sept in numerous areas. He said he met Galati for the first time when Galati and two of his underage friends approached him at a convenience store and asked him to buy them some beer. Contrary to Sept’s testimony, Middlebrooks said he and Galati walked to Van Hill’s apartment and that Galati and Middlebrooks bought drugs from someone outside the apartment—not from Sept. Middlebrooks said that he and Galati parted ways, though Galati said he would come back later to see Dvorsky. Middlebrooks said that when he returned to the apartment, Galati was there but Puckett was not. Middlebrooks said he did not see what happened to Galati because he was in the bathroom.

Scott-Bostic testified that she did not remember much of the evening because she had smoked crack and drank a bottle of cognac while taking prescription medication. When detectives questioned her before trial, she was unable to identify Dvorsky or Galati and said that Jaymo was not in the apartment that night. She said she was in the bathroom when she heard a commotion. When she came out, Puckett yelled at her to get back in the bathroom. During cross-examination, Scott-Bostic insisted that was the same account she gave to detectives, but subsequently the prosecution and the defense presented an agreed statement that Scott-Bostic told detectives it was Sept, not Puckett, who told her to stay in the bathroom.

The defense called no witnesses. Puckett’s sister was going to testify that he spent the evening of Thursday, March 12 at a barbeque at his mother’s boyfriend’s house, left at 10 pm, returned about 11:30 p.m., and then spent the night there. The defense had not interviewed the alibi witnesses, apparently believing they were of no help based on Sept’s testimony about the motel room and the discovery of the body on Saturday March 14, suggesting that the murder occurred on March 13.

During closing argument, the prosecution argued there was no evidence that Jaymo stayed at the apartment or was involved at all.

On February 8, 2002, after three days of deliberation, the jury convicted Puckett of first-degree murder and robbery, but acquitted him of illegal use of a firearm, apparently rejecting the prosecution’s argument that he pulled the trigger. Puckett was sentenced to life in prison without parole.

His conviction was upheld on appeal in 2003. For more than a decade, Puckett tried to set aside his conviction. In 2014, the Northern California Innocence Project (NCIP) took up Puckett’s case, and was later joined by the law firm of Simpson Thacher & Bartlett. By that time, all the physical evidence—including fingernail scrapings from Galati—had been destroyed by the Sacramento County Sheriff’s Department.

The re-investigation showed that in fact the motel room had been rented at 4:20 a.m. on March 13, 1998—when Puckett was in bed at his mother’s boyfriend’s home after the barbeque. The prosecution would ultimately agree the evidence had been mischaracterized at the trial.

In addition, more than 700 pages of police reports and interviews, much of it in the file of the Dvorsky murder investigation, were discovered that contained evidence favorable to Puckett.

The documents that the prosecution failed to disclose to Puckett’s defense attorney included Sept’s prior criminal records, the fact that prison officials took Sept’s DNA sample 12 days before he first came forward to implicate Puckett, that Dvorsky and Jaymo had a history of committing robberies together, and that Scott-Bostic had a criminal record and close ties to Jaymo. The defense also was unaware that Sept’s plea agreement resulted in a reduction by about a year of his sentence in the unlawful discharge of a firearm case for which he was in prison when he first implicated Puckett.

Moreover, despite the prosecution’s suggestion in opening statements in Puckett’s trial and claim to the judge that he was linked to Dvorsky’s murder, the Dvorsky murder file did not contain a single reference to Puckett, according to a review of the entire file by volunteer NCIP attorney Karyn Sinunu-Towery.

The prosecution also failed to disclose evidence that Puckett had no connection to Dvorsky. Her journal, consisting of hundreds of pages, had the names of 121 men and the name mentioned most frequently was Jaymo.

In September 2017, Puckett’s legal team—NCIP legal director Linda Starr and Sinunu-Towery, as well as lawyers from Simpson Thacher & Bartlett—filed a state petition for a writ of habeas corpus. Besides seeking to vacate the conviction on the basis of the undisclosed evidence, the petition said that Puckett’s trial defense attorney had provided an inadequate legal defense by failing to confront Sept with his recantation and failing to present an alibi defense.

The petition also noted that in 2015, Jaymo Reeves’s estranged wife, Connie Goins, provided a sworn statement. In it, she said that Jaymo had said that Puckett had nothing to do with the murder and robbery of Galati because Jaymo was there and Puckett was not.

On March 3, 2020, Superior Court Judge Steve White granted the petition, vacated Puckett’s convictions and ordered a new trial.

Judge White noted that Puckett’s legal team contended that the prosecution had withheld more than “700 pages of material exculpatory evidence. [The prosecution] concedes a vast majority of the referenced evidence was withheld.

“The question for this Court is whether the evidence withheld is exculpatory or favorable to [Puckett].

“It is.”

On March 13, 2020, the prosecution dismissed the charges and Puckett was released.

– Maurice Possley

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Posting Date: 3/31/2020
State:California
County:Sacramento
Most Serious Crime:Murder
Additional Convictions:Robbery
Reported Crime Date:1998
Convicted:2002
Exonerated:2020
Sentence:Life without parole
Race/Ethnicity:Black
Sex:Male
Age at the date of reported crime:21
Contributing Factors:Mistaken Witness ID, Perjury or False Accusation, Official Misconduct, Inadequate Legal Defense
Did DNA evidence contribute to the exoneration?:No