Perry Alexander Taylor v. Secretary, Florida Department of Corrections, 760 F.3d 1284

In 1989 Perry Taylor was convicted of first-degree murder and sexual battery for the brutal killing of Geraldine Birch; the State relied on Taylor’s detailed confessions and forensic injuries inconsistent with consensual sex.
Defense theory at trial: the killing was second-degree (depraved mind) arising from consensual sex after Birch allegedly offered sex for money/drugs; Taylor testified to that effect and demonstrated his physical strength to the jury.
Trial court excluded proffered testimony from three of the victim’s sisters that Birch had occasionally used or purchased crack months before her death; the court found those accounts irrelevant and remote to the consent issue.
Postconviction, Taylor claimed (1) due process violation for exclusion of the sisters’ testimony and (2) ineffective assistance because counsel called him to testify without preparation and had him reenact the killing; state courts denied relief.
Federal habeas petition raised these claims; the district court denied relief and this Court granted a Certificate of Appealability on the two issues above and affirmed the denial of habeas relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exclusion of the victim’s sisters’ testimony denied due process/Chambers right to present a defense	Excluded testimony that Birch used/purchased crack would corroborate Taylor’s consent defense and was constitutionally protected corroborative evidence	Evidence was irrelevant and remote; exclusion was a state evidentiary ruling that did not deprive Taylor of a fair trial	Exclusion was not unconstitutional; testimony was too remote/attenuated and not "crucial" so no due process violation
Whether trial counsel rendered ineffective assistance by calling Taylor to testify and allegedly directing a reenactment without preparation (Strickland)	Counsel acted unreasonably in placing an unprepared Taylor on the stand and having him reenact violent acts, causing prejudice	Counsel made a strategic, reasonable choice to have Taylor testify to present the only viable defense given confessions and limited corroboration; no deficient performance shown	No deficient performance under Strickland; strategic decision within wide range of reasonable conduct; habeas relief denied

Chambers v. Mississippi, 410 U.S. 284 (1973) (exclusion of critical corroborative evidence can violate due process)
Crane v. Kentucky, 476 U.S. 683 (1986) (defendant has a meaningful opportunity to present a complete defense)
Strickland v. Washington, 466 U.S. 668 (1984) (standards for ineffective assistance of counsel: performance and prejudice)
Estelle v. McGuire, 502 U.S. 62 (1991) (federal habeas courts do not generally reexamine state evidentiary rulings unless they render trial fundamentally unfair)
Lisenba v. California, 314 U.S. 219 (1941) (habeas relief only where error so infused trial with unfairness as to deny due process)
Washington v. Texas, 388 U.S. 14 (1967) (defendant’s compulsory process right to obtain witnesses)
Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA deference and the high bar for federal habeas relief)