State v. Taylor
2020 Ohio 3481
Ohio Ct. App.2020Background
- On November 26, 2017 a silver Chevrolet Monte Carlo (driven by Jamariyo Drane with Jermichael Taylor as passenger) was involved in a shooting and subsequent crash; a .380 semi‑automatic handgun with an empty magazine was recovered from the vehicle. A bystander, Shavoria Williams, was shot in the leg.
- After the crash Taylor and Drane broke into a 70‑year‑old woman's home to clean injuries; they later fled. Taylor left medical care early and was not located for about eight months.
- Taylor was arrested on a post‑release‑control (PCR) warrant, his PCR was revoked, and he was later indicted on felonious assault (two counts), burglary, and having a weapon while under disability; firearm specifications accompanied several counts.
- At trial the jury convicted Taylor on all counts; the court merged the assault counts and imposed consecutive sentences (aggregate 28 years including firearm specification terms).
- On appeal Taylor raised three assignments of error: (1) trial court erred by refusing to remove a juror who may have had outside knowledge; (2) his speedy‑trial rights were violated; and (3) the court erred in denying a formal competency evaluation and finding him competent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court abused its discretion by refusing to remove Juror #10 | Juror #10 had not actually accessed any video relating to this case; he volunteered a possible concern and, after inquiry, confirmed impartiality; no misconduct shown | Juror #10 sometimes pulls crime videos for police and may have seen similar footage that could taint his perceptions | Court affirmed: no abuse of discretion; juror denied any involvement with footage from this case and stated he could be impartial |
| Whether Taylor was denied his statutory speedy‑trial rights | State: triple‑count did not apply (Taylor was in custody for PCR), only 270 days applied; actual time between booking and trial was 119 days; additional tolling applied (defendant continuance, joining co‑defendant motions, competency inquiries, and a reasonable court continuance) | Taylor: trial scheduled outside the applicable speedy‑trial period; rights violated | Court affirmed: no speedy‑trial violation; tolling and continuances rendered trial timely |
| Whether the trial court erred in denying a formal competency evaluation and finding Taylor competent | State: court conducted an on‑the‑record inquiry; Taylor communicated, understood rights and proceedings, had prior criminal experience, and did not present evidence raising a bona fide doubt of competence | Taylor: counsel and mother reported he did not understand counsel and was intellectually limited; requested formal evaluation three days before trial | Court affirmed: no abuse of discretion; on‑the‑record inquiry dispelled bona fide doubt and ordering an evaluation was not required |
Key Cases Cited
- State v. Darmond, 135 Ohio St.3d 343 (2013) (abuse‑of‑discretion review for trial‑court rulings)
- State v. Berry, 72 Ohio St.3d 354 (1995) (Dusky competence standard and competency principles)
- Dusky v. United States, 362 U.S. 402 (1960) (benchmark test for competency to stand trial)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (standard for finding abuse of discretion)
- State v. Mincy, 2 Ohio St.3d 6 (1982) (requirements for court entry when granting continuances under speedy‑trial tolling)