The three-justice panel from California's 2nd District Court of Appeal found that Shanker Patel's behavior on the day his wife Usha was stabbed to death "strongly supported the inference he was attempting to create an alibi.''
"Although most of the evidence against defendant was circumstantial, it was ample,'' the panel's 43-page ruling says.
Patel was convicted in January 2017 of first-degree murder, and jurors also found true the special circumstance allegation of murder while lying in wait.
His wife was on her way to pick up their 7-year-old daughter from school when she was attacked in the garage of the couple's home on Nov. 19, 1991. The 29-year-old aspiring lawyer's body -- which was bound -- was found in the trunk of her car, which had been driven to a nearby school. Authorities determined that she had suffered more than 20 stab wounds, mostly to the chest and neck area.
A renewed investigation into the cold case in 2010 revealed DNA inside gloves discovered on the front passenger seat of the victim's car, authorities said. That DNA was linked to Miguel Angel Garcia, who subsequently pleaded no contest to first-degree murder and was sentenced in May 2013 to 25 years to life in state prison.
Investigators determined that Patel paid a middleman $7,500 to organize his wife's killing, then provided details for when the hitman should be in the family's home to kill his wife, Deputy District Attorney John Monaghan said after Patel's conviction.
Patel was having an affair before his wife's killing, and his wife was planning to leave him after she passed the California bar exam, according to testimony presented at his trial.
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Patel was charged in 2013 with his wife's murder, apprehended in Atlanta and brought back to California to stand trial. He is serving a life prison term without the possibility of parole.
