State v. Taylor
2018 Ohio 2921
Ohio Ct. App.2018Background
- On Memorial Day 2016 at an Akron apartment complex, Fred Taylor, Jr. attended a cookout where Javon Knaff was shot multiple times and later died.
- Eyewitness D.H.-B. heard a first shot, looked up, and saw Taylor fire additional shots at Knaff; Knaff collapsed and repeatedly said he was dying.
- Officer Walter rode with Knaff to the hospital; Knaff identified his shooter aloud as "Fred" before dying roughly two hours after the shooting.
- Taylor fled the state the same night; was later apprehended in West Virginia after giving false identifying information.
- Indicted for purposeful murder, felony murder (with underlying felonious assault), two counts of felonious assault, and weapons-under-disability; convicted of felony murder, felonious assault (merged), firearm specification, and weapons-under-disability; sentenced to 15 years-to-life plus firearm and concurrent disability terms.
- On appeal Taylor argued (1) the admission of Knaff's out-of-court statement violated hearsay rules and the Confrontation Clause, and (2) insufficiency and manifest-weight of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Knaff's out-of-court identification of shooter | State: statement was admissible as a dying declaration (hearsay exception) | Taylor: statement was hearsay and testimonial; admission violated the Sixth Amendment | Court: Statement was a dying declaration; Confrontation Clause does not bar admission of dying declarations; admission proper |
| Whether dying-declaration doctrine survives Crawford | State: dying declarations are a historical exception to confrontation and remain viable | Taylor: Crawford requires prior opportunity to cross-examine testimonial statements | Court: Joins other Ohio districts and holds dying-declaration exception remains post-Crawford |
| Sufficiency of evidence for felony murder/felonious assault | State: eyewitness testimony, dying declaration, and other evidence sufficiently proved assault and causal link to death | Taylor: only one eyewitness, no DNA, and contested ID; Walter's testimony should be excluded | Court: Viewing evidence in prosecution's favor, evidence sufficient to sustain convictions |
| Manifest weight of the evidence | State: jury credited eyewitnesses and investigators; no miscarriage of justice | Taylor: eyewitness unreliability, investigative gaps, alternative suspects | Court: After weighing credibility and conflicts, jury verdict not against manifest weight; not an exceptional case to overturn |
Key Cases Cited
- Crawford v. Washington, 541 U.S. 36 (discusses confrontation and testimonial evidence)
- Giles v. California, 554 U.S. 353 (recognizes historical exceptions to confrontation, including dying declarations and forfeiture)
- State v. McKelton, 148 Ohio St.3d 261 (Ohio 2016) (addresses Confrontation Clause post-Crawford)
- State v. Thompkins, 78 Ohio St.3d 380 (distinguishes sufficiency and weight standards)
- State v. Jenks, 61 Ohio St.3d 259 (standard for sufficiency review)
- Mattox v. United States, 146 U.S. 140 (historical consideration of dying declarations)