State v. Taylor
161 So. 3d 963
La. Ct. App.2015Background
- On Sept. 12, 2008, the decomposed body of 18‑year‑old Tavia Sills (five months pregnant) was found in a pond; LaMondre Tucker became the lead suspect and later implicated Marcus Andrew Taylor.
- Tucker confessed and said Taylor was present; Taylor initially denied involvement but later, in multiple interviews with Detective Rod Demery (Sept. 15, 17, 18, 2008), admitted assisting Tucker and gave detailed, recorded statements and a recorded walk‑through of the scene.
- Taylor was indicted (amended) for second‑degree murder (later convicted of manslaughter by jury) and moved to suppress: (1) a buccal swab (no warrant) and (2) his statements on grounds of intellectual disability and inability to validly waive Miranda rights.
- A sanity/competency evaluation produced conflicting expert opinions: Drs. Seiden and Pinkston found Taylor (IQ ≈56) incompetent to stand trial; Drs. Colon and Turpin (and Dr. Chafetz re: malingering) found him competent and able to waive rights and assist counsel.
- The trial court found Taylor competent, denied suppression of statements, the jury convicted him of manslaughter, and the court sentenced him to 30 years at hard labor; Taylor appealed raising competency, Miranda waiver, and excessive sentence claims.
Issues
| Issue | Taylor's Argument | State's Argument | Held |
|---|---|---|---|
| Competency to stand trial | Taylor (relying on Drs. Seiden & Pinkston): IQ ≈56; cannot understand legal concepts, assist counsel, or withstand trial stress — thus incompetent | State (Drs. Colon & Turpin): despite low IQ, Taylor understood charges/rights, could recall facts and assist counsel; trial court should defer to voir dire of experts | Trial court's finding of competency affirmed; no abuse of discretion given record and conflicting expert testimony (trial court decision entitled to great weight) |
| Voluntary, knowing Miranda waiver / admissibility of statements | Taylor: mental retardation prevented comprehension of Miranda rights; statements involuntary or unknowing | State: detectives advised rights at each interview, recordings show Taylor understood, answered coherently, volunteered and corroborative details; no coercion | Denial of suppression affirmed; totality of circumstances supports knowing, voluntary waiver and admissibility |
| Excessive sentence (30 yrs hard labor for manslaughter) | Taylor: court undervalued his mental retardation, lack of criminal history, and that Tucker was shooter/agent provocateur | State: sentence within statutory limits; court considered La. C. Cr. P. art. 894.1 factors and seriousness; lesser term would deprecate offense | Sentence affirmed; not grossly disproportionate or an abuse of discretion |
Key Cases Cited
- State v. Bennett, 345 So.2d 1129 (La. 1977) (factors for assessing competency to stand trial)
- State v. Holmes, 5 So.3d 42 (La. 2008) (presumption of sanity; burden to prove incompetency by preponderance)
- State v. Odenbaugh, 82 So.3d 215 (La. 2010) (due process protection against trial while incompetent)
- State v. Anderson, 996 So.2d 973 (La. 2008) (appellate deference to trial court competency determinations)
- State v. Tart, 672 So.2d 116 (La. 1996) (diminished capacity does not automatically invalidate Miranda waiver; voluntariness assessed under totality of circumstances)
- State v. Smith, 839 So.2d 1 (La. 2003) (constitutional standard for excessive sentence review)