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State of Iowa v. William Lamont Taylor
15-2128
| Iowa Ct. App. | Mar 8, 2017
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Background

  • Early morning traffic stop: officers pursued a Mercury Mountaineer driven by William Taylor when it lacked proper plates; Taylor fled at high speeds through interstate and neighborhoods.
  • After about four miles, Taylor drove onto his yard, made a U-turn on the grass, revved the engine, and rammed head-on into Officer Trevor Spear’s squad car; three dash-cams recorded the events.
  • Taylor was arrested, admitted fleeing because of an outstanding warrant, and was charged with assault on a peace officer with a dangerous weapon (Iowa Code § 708.3A(2)) and eluding (§ 321.279(2)); he stipulated to prior felonies for habitual-offender enhancement.
  • At trial, officers testified they believed the collision was intentional; videos were presented for the jury to view Taylor’s driving and maneuvers.
  • The jury convicted Taylor of assault with a dangerous weapon and eluding; the district court sentenced him to 15 years with a 3-year mandatory minimum.
  • On appeal Taylor challenged (1) sufficiency of evidence to prove specific intent to assault and (2) ineffective assistance for failure to impeach officers with prior testimony; he also filed a pro se supplemental brief raising unrelated claims.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of evidence of specific intent to assault a peace officer State: officers’ testimony and dash-cam videos support an inference Taylor intended to injure or place the officer in fear Taylor: he was fleeing; conduct at most reckless, not intentional assault Affirmed — substantial evidence supported inference of specific intent; jury could credit officers and video evidence
Ineffective assistance for not impeaching officers with prior testimony State: trial counsel’s cross-examination was competent; prior statements were materially consistent Taylor: counsel refused to cross-examine officers using deposition/prelim testimony inconsistencies Affirmed — no breach of duty; record shows no material inconsistencies to impeach
Pro se claims about jail medical care and transcript discrepancies N/A (not relevant to contesting conviction) Taylor: alleged medical neglect and transcript discrepancies Denied — medical claim seeks relief outside appeal; transcript claim undeveloped and not shown prejudicial
Alleged prosecutorial misconduct (barely argued) N/A Taylor: listed heading but offered no analysis or authority Not considered — issue inadequately briefed and waived

Key Cases Cited

  • State v. Reed, 875 N.W.2d 693 (Iowa 2016) (standard for reviewing sufficiency of the evidence)
  • State v. Rohm, 609 N.W.2d 504 (Iowa 2000) (definition of substantial evidence and viewing evidence in the light most favorable to the verdict)
  • State v. Chatterson, 259 N.W.2d 766 (Iowa 1977) (specific intent inferred from facts and natural consequences of intentional acts)
  • State v. Thorndike, 860 N.W.2d 316 (Iowa 2015) (de novo review for ineffective-assistance claims grounded in the Sixth Amendment)
  • Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance: deficient performance and prejudice)
  • State v. Shanahan, 712 N.W.2d 121 (Iowa 2006) (failure to prove either Strickland prong is fatal)
  • State v. Palmer, 791 N.W.2d 840 (Iowa 2010) (preservation of ineffective-assistance claims and postconviction relief considerations)
  • State v. Rice, 543 N.W.2d 884 (Iowa 1996) (competence of defense counsel’s cross-examination and deference to counsel’s tactical choices)
  • State v. Oldfather, 306 N.W.2d 760 (Iowa 1981) (automobile may be a dangerous weapon when used to indicate intent to inflict serious injury)
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Case Details

Case Name: State of Iowa v. William Lamont Taylor
Court Name: Court of Appeals of Iowa
Date Published: Mar 8, 2017
Docket Number: 15-2128
Court Abbreviation: Iowa Ct. App.