State Ex Rel. Taylor v. Steele
2011 Mo. LEXIS 125
| Mo. | 2011Background
- Taylor abducted, raped, and murdered Ann Harrison in 1989; he pleaded guilty in 1991 to first-degree murder, armed criminal action, kidnapping, and forcible rape; he chose to be sentenced by a judge, not a jury; Judge Randall imposed a death sentence after finding aggravating factors; on remand (Taylor I) a new penalty hearing was conducted by Judge Coburn leading to another death sentence; subsequent post-conviction relief was denied and Taylor sought habeas corpus relief arguing the judge—not the jury—imposed the death sentence and that the sentence violated constitutional rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ring/Apprendi/Blakely apply retroactively to require jury sentencing | Taylor claims Ring retroactivity entitles jury sentencing. | Court holds Ring retroactivity limited and distinguishable; waiver framework controls. | No retroactive entitlement to jury sentencing based on waiver and law-of-the-case principles. |
| Whether Taylor validly waived jury sentencing in 1991 | Taylor did not knowingly waive Sixth Amendment jury sentencing rights. | Taylor knowingly chose judge sentencing as strategic decision. | Taylor knowingly and strategically waived jury sentencing; waiver is valid. |
| Whether Taylor’s equal protection/due process claims merit relief | Similarly situated defendants received life rather than death; argues unequal treatment. | Different factual/posture; waivers and retroactivity apply; no retroactive proportionality review. | Claims rejected; no retroactive proportionality review and no equal-protection relief. |
| Whether Ring applies to cases where the defendant pleaded guilty | Apprendi/Ring/Blakely require jury fact-finding even after guilty plea. | Waiver and case posture distinguish; Blakely allows valid waiver of jury fact-finding. | Ring/Blakely apply in defendant’s context, but waiver-based retroactivity limits relief; court denies habeas relief. |
Key Cases Cited
- Apprendi v. New Jersey, 530 U.S. 466 (2000) (jury must find facts increasing penalty beyond the jury verdict)
- Ring v. Arizona, 536 U.S. 584 (2002) (jury must determine aggravating factors in capital cases)
- Blakely v. Washington, 542 U.S. 296 (2004) (jury findings required for punishment enhancements; allowed waivers)
- Whitfield v. State, 107 S.W.3d 253 (Mo. banc 2003) (retroactivity of Ring; judge-found death sentence defective when jury deadlocks)
- Halbert v. Michigan, 545 U.S. 605 (2005) (cannot waive rights not yet recognized; limits on waivers)
- State v. Nunley, 341 S.W.3d 611 (Mo. banc 2011) (companion case addressing retroactivity and waiver in similar context)
- State v. Piper, 709 N.W.2d 783 (S.D. 2006) (waiver analysis in guilty-plea sentencing contexts; distinguishable from Taylor)
- Taylor v. Bowersox, 329 F.3d 963 (8th Cir. 2003) (federal habeas relating to plea validity and sentencing)