Michael Deon Taylor v. State of Mississippi, 167 So. 3d 1143

Michael Deon Taylor was convicted (2012) of possessing stolen property and sentenced to ten years as a habitual offender.
Photographs linking Taylor to the alleged purchase of the stolen skid steer were recovered from his phone; the owner initially said he bought the skid steer from someone else but later identified Taylor.
Defense counsel filed a pretrial Motion in Limine to exclude Taylor’s past criminal history; the motion was withdrawn immediately before Taylor testified.
Taylor testified in his own defense and admitted one prior felony on direct examination.
On cross-examination the State elicited detailed testimony about seven or eight prior felony convictions; defense counsel made no objections.
The Court of Appeals affirmed on the merits but left ineffective-assistance claims for post-conviction review; the Mississippi Supreme Court granted certiorari and reversed on ineffective-assistance grounds, ordering a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel’s failure to object to expansive cross-examination about numerous prior felonies amounted to ineffective assistance of counsel	Taylor: counsel’s withdrawal of the Limine motion and failure to object was deficient and prejudicial	State: evidence of prior convictions was proper impeachment once Taylor testified; counsel’s actions were trial strategy	Held: Counsel was ineffective; failure to object was deficient and prejudiced Taylor—reversed and remanded for new trial
Whether the probative value of detailed conviction history outweighed its prejudicial effect under M.R.E. 609	Taylor: detailed listing of 7–8 felonies was highly prejudicial and not sufficiently probative given trial’s credibility focus	State: impeachment by prior convictions is permissible to attack credibility of testifying defendant	Held: The detailed cross-examination was more prejudicial than probative in this credibility-driven case; judge made no requisite on-the-record balancing
Whether a defendant’s decision to testify waives protections against introduction of prior bad acts	Taylor: Testifying does not remove Rule 404(b)/609 protections; a stipulation to felon status is a recognized limiting strategy	State: By testifying, defendant opened door to inquiry into convictions	Held: Testifying does not eliminate Rule 404(b)/609 safeguards; counsel should have limited inquiry or sought a stipulation; extensive detail was improper

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong standard for ineffective assistance of counsel)
Read v. State, 430 So. 2d 832 (Miss. 1983) (appellate courts may reach ineffectiveness on direct appeal when record affirmatively shows deficiency)
Peterson v. State, 518 So. 2d 632 (Miss. 1988) (framework for assessing probative value vs. prejudice for impeachment by convictions)
Herrington v. State, 102 So. 3d 1241 (Miss. Ct. App. 2012) (discusses trial strategy and use of stipulations to limit prejudice from prior convictions)