Jeffery L. Taylor v. State of Indiana (mem. dec.)
84A04-1609-CR-2254
| Ind. Ct. App. | Apr 25, 2017Background
- On Sept. 5, 2015, Jeffery Taylor and his girlfriend Aurora Garcia drank all day and got into an evening argument.
- Taylor allegedly grabbed a knife and attempted to stab Garcia; she blocked the attempt with her left wrist, which was cut and bleeding.
- Taylor took Garcia’s phone, prevented her from calling for help, and she later fled to a neighbor to call police after Taylor fell asleep.
- Garcia reported to police that Taylor stabbed her; at the hospital hours later her BAC was 0.161 and she testified to multiple mental-health diagnoses and memory problems.
- The State charged Taylor with criminal confinement (Level 3 felony), battery by means of a deadly weapon (Level 5 felony), and domestic battery (Class A misdemeanor); a jury convicted him of battery by means of a deadly weapon.
- Taylor received a five-year sentence and appealed, arguing Garcia’s testimony was incredibly dubious and insufficient to support conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to support battery by means of a deadly weapon | State: Garcia’s consistent assertion that Taylor stabbed her plus circumstantial facts support conviction | Taylor: Garcia’s testimony was unreliable (intoxicated, mental-health diagnoses, memory lapses) and thus incredibly dubious, so evidence is insufficient | Affirmed: testimony and circumstantial evidence were sufficient; incredible-dubiosity rule does not apply |
Key Cases Cited
- Wright v. State, 828 N.E.2d 904 (Ind. 2005) (standard for sufficiency review and deference to jury credibility determinations)
- Smith v. State, 34 N.E.3d 1211 (Ind. 2015) (explaining the "incredible dubiosity" rule and its three-part test)
- Moore v. State, 27 N.E.3d 749 (Ind. 2015) (noting the high bar to apply incredible-dubiosity and that testimony must be contrary to human experience)
- Gaddis v. State, 251 N.E.2d 658 (Ind. 1969) (discussing insufficiency where sole witness is unsure of identity)
- Edwards v. State, 753 N.E.2d 618 (Ind. 2001) (jury’s role in assessing witness credibility when weaknesses are presented)