State v. Taylor
2011 Ohio 1866
Ohio Ct. App.2011Background
- Taylor was indicted on eight counts including two counts of aggravated murder, two counts of attempted aggravated murder, two counts of aggravated burglary, one count of felonious assault, and one count of having weapons while under disability, each with a firearm specification.
- A jury trial in May 2010 resulted in GUILTY verdicts on counts 1, 2, 5, 6, and 7, and NOT GUILTY on counts 3 and 4; count 8 was dismissed without prejudice.
- The trial court sentenced Taylor to life without parole on count 1 plus a three-year firearm specification, ordered counts 2 and 1 merged, imposed ten years on count 5, count 6 merged, and eight years on count 7, with consecutive terms totaling life without parole plus twenty-one years; the firearm specification term was to be served first.
- Taylor filed a notice of appeal on June 30, 2010, advancing ten assignments of error challenging the convictions and sentencing.
- The court of appeals affirmed, addressing manifest-weight challenges, evidentiary rulings, ineffective-assistance claims, cumulative error, and sentencing findings under Oregon v. Ice standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight of evidence for aggravated murder | Taylor argues the aggravated murder convictions are against the manifest weight of the evidence. | Taylor contends the State failed to prove guilt beyond the weight of the evidence. | Not against the manifest weight; affirmed. |
| Weight of evidence for aggravated burglary | Taylor argues the aggravated burglary convictions are against the manifest weight of the evidence. | Taylor contends the state failed to prove elements and intent beyond weight of the evidence. | Not against the manifest weight; affirmed. |
| Admission of Lt. Shenefield's testimony on truthfulness | Taylor challenges testimony that hysterical people tell the truth as to Rhonda’s credibility. | State claims invited error; door opened by defense during cross-examination. | Invited error; not reversible; meritless. |
| Impeachment foundation for Elizabeth Shipman’s untruthfulness | Taylor argues the court erred by limiting witnesses on Elizabeth’s reputation for untruthfulness. | Defense contends witnesses lacked proper foundation to attest to reputation. | No abuse of discretion; rulings sustained; no prejudice shown. |
| Cumulative error and sentencing findings | Taylor argues cumulative errors and failure to make required findings under 2929.14(E)(4) after Ice. | State contends no mandatory findings were required post-Ice; no reversible cumulative error. | No reversible error; sentence affirmed. |
Key Cases Cited
- State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest weight review; credibility assessment)
- State v. DeHass, 10 Ohio St.2d 230 (1967) (weight and credibility standard)
- State v. Martin, 20 Ohio App.3d 172 (1983) (weighing evidence and witness credibility on appeal)
- Krischbaum v. Dillon, 58 Ohio St.3d 58 (1991) (trial court discretion; evidentiary rulings)
- State v. Chappell, 97 Ohio App.3d 515 (1994) (invited error and evidentiary limits)