State v. Taylor, 2016 Ohio 5541

Victim Myreon Mazur was brutally beaten and later died; Shawn D. Taylor was among several men charged in the attack.
Taylor was convicted by jury (2007) of robbery, two counts of kidnapping, felony murder (proximate result of kidnapping), and involuntary manslaughter; convictions later affirmed on direct appeal except for merger of robbery and one kidnapping count.
Taylor’s conviction became final after the Ohio Supreme Court denied review and a federal habeas petition was dismissed.
In September 2015 Taylor filed a pro se post-conviction motion claiming the murder verdict form was defective because it lacked (a) a mens rea finding (‘‘purposely’’) and (b) a separate jury finding that the death was the proximate result of the predicate felony (kidnapping).
Trial court denied relief, holding R.C. 2903.02(B) (felony-murder) does not require purpose to kill and that the jury’s signed verdict encompassed the proximate-result theory; court also found claims barred by res judicata. The appellate court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Taylor)	Held
Whether felony-murder under R.C. 2903.02(B) requires a mens rea finding that the defendant acted "purposely"	R.C. 2903.02(B) does not require purpose to kill; intent for predicate felony suffices	Verdict was defective because it omitted a required "purposely" element	Held: No purposeful intent required; felony-murder is strict liability for intent to kill (conviction valid)
Whether the jury verdict form was fatally incomplete because it lacked an explicit finding that death was the proximate result of kidnapping	No statute required a special/verbatim separate verdict finding; signed verdict titled "Murder (Proximate Result of Kidnapping)" was sufficient	Verdict form lacked a space for the jury to make the proximate-cause/predicate-felony finding; trial court lacked jurisdiction to accept it	Held: No statutory mandate for a special verdict; verdict sufficient; claim also barred by res judicata
Whether the verdict-form defect rendered the judgment void and thus not subject to res judicata	Res judicata bars claims that could have been raised on direct appeal; voidness exception is narrow (postrelease control context)	Form defect rendered conviction void, so res judicata should not apply	Held: Voidness doctrine limited; defendant’s challenge was reviewable on direct appeal and is barred by res judicata

State v. Nolan, 141 Ohio St.3d 454, 2014-Ohio-4800, 25 N.E.3d 1016 (felony-murder imposes liability without intent to kill)
State v. Miller, 96 Ohio St.3d 384, 2002-Ohio-4931, 775 N.E.2d 498 (R.C. 2903.02(B) lacks mens rea requirement)
State v. Fry, 125 Ohio St.3d 163, 2010-Ohio-1017, 926 N.E.2d 1239 (same principle regarding felony-murder)
State v. Cook, 65 Ohio St.3d 516, 605 N.E.2d 70 (special jury verdicts required only when statute mandates)
State v. Jenkins, 15 Ohio St.3d 164, 473 N.E.2d 264 (discussing special verdict necessity)
State v. Dunlap, 73 Ohio St.3d 308, 652 N.E.2d 988 (same)
State v. McDonald, 137 Ohio St.3d 517, 2013-Ohio-5042, 1 N.E.3d 374 (verdict forms must reflect statutory aggravating elements when degree is elevated)
State v. Pelfrey, 112 Ohio St.3d 422, 2007-Ohio-256, 860 N.E.2d 735 (statutory requirement for special verdict language when degree depends on additional elements)
State v. Fischer, 128 Ohio St.3d 92, 2010-Ohio-6238, 942 N.E.2d 332 (void-sentence/res judicata limits; narrow voidness exception)
State v. Saxon, 109 Ohio St.3d 176, 2006-Ohio-1245, 846 N.E.2d 824 (res judicata promotes finality; bars relitigation of issues that could have been raised earlier)