State of Louisiana v. Wayne G. Taylor A/K/A Wayne Taylor, 166 So. 3d 988

Background

Defendant Wayne G. Taylor was tried by a six‑person jury on two counts of simple burglary; convicted of unauthorized entry of a place of business (one count) and acquitted on the other; sentenced to six years at hard labor. Appellate court reversed for insufficient evidence; Louisiana Supreme Court granted review.
Two massive copper‑theft incidents occurred at a large Plaquemines Parish government property in Jan–Feb 2011; damage indicated use of a vehicle to pull wiring and forced entry into buildings.
Investigators recovered a cigarette lighter at the Jan. scene and blood drops and other indicia of forcible interior entry at the Feb. scene. DNA profiles from both scenes matched Taylor’s CODIS profile; lab testimony indicated an extremely low random match probability for the blood sample.
No copper wire, fingerprints, or wiring recovered from Taylor; no direct eyewitness placing him at the scenes. Taylor denied prior presence in Plaquemines Parish at booking; buccal swab after arrest confirmed DNA matches.
The Fourth Circuit reversed, finding the State failed to prove contemporaneous unauthorized interior entry and business use; the Supreme Court reversed, reinstating conviction and remanding remaining claims to the court of appeal.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Taylor)	Held
Sufficiency of evidence to support conviction for unauthorized entry/place of business	DNA at two scenes (lighter and blood), scene evidence of interior forced entry and similar modus operandi supported inference Taylor was on premises during thefts	DNA evidence alone did not prove when blood was deposited; photographs and lack of cleaning/maintenance evidence left reasonable doubt as to contemporaneous unauthorized interior entry	Reversed Court of Appeal; evidence viewed in light most favorable to prosecution was sufficient for jury to find guilt beyond reasonable doubt
Whether blood and lighter DNA established contemporaneous presence at respective incidents	Lighter appeared a "fresh drop"; blood and lighter DNA linked Taylor to incidents; similar method of theft tied incidents together showing contemporaneous involvement	Blood could have been deposited earlier (state‑school era); lighter DNA mixture and imperfect allele testimony weakened inference of contemporaneity	Held for State: jurors reasonably could credit experts and infer contemporaneity given totality of evidence
Use of Taylor’s booking statement denying prior presence (consciousness of guilt)	Booking denial was admissible and jurors could infer lying indicated guilty consciousness	Alleged invocation of right to silence and improper admission; contention raised but pretermitted on appeal	Supreme Court accepted jurors could treat the denial as evidence of consciousness of guilt (issue remanded for unresolved assignments)
Whether building was a "place of business" under burglary statute	Buildings were used by Plaquemines Parish for archival/storage and parish operations; responsive verdict of unauthorized entry of a place of business is statutorily available	Argued archival storage may not qualify as a business under R.S. 14:62	Court held evidence could support the lesser statutory responsive verdict (unauthorized entry of a place of business); conviction on that responsive verdict sustained

Key Cases Cited

Jackson v. Virginia, 443 U.S. 307 (established standard for sufficiency review under due process)
State v. Captville, 448 So.2d 676 (La. 1984) (circumstantial‑evidence framework; rejection of defendant’s hypothesis supports conviction)
State v. Hearold, 603 So.2d 731 (La. 1992) (when entirety of evidence supports conviction, appellate court must consider trial errors)
State v. Juluke, 725 So.2d 1291 (La. 1999) (defendant may not advance inconsistent defenses across forums on sufficiency review)
State ex rel. Elaire v. Blackburn, 424 So.2d 246 (La. 1982) (responsive/lesser verdicts and appellate review when defendant fails to object)