State v. Taylor
382 S.W.3d 251
Mo. Ct. App.2012Background
- Deonta R. Taylor is convicted in Jackson County Circuit Court of two counts of first-degree murder and two counts of armed criminal action for a February 6, 2009 double homicide at Gerry’s Silver Slipper in Kansas City, Missouri.
- Eyewitnesses Robinson and Harper identified Taylor as the shooter from photo lineups, aided by a security-ID scanning system showing his entry into the club shortly before the murders.
- The crime scene yielded shell casings and multiple gunshot victims; a different gun was later recovered from Elvie Black, who was fleeing at the scene.
- DNA testing of a door-handle sample produced a minor contributor profile that could not exclude Taylor as a possible source; the major contributor differed and did not conclusively identify him.
- A detective testified that the club’s ID-scanning system retained records of entrants, and the manager testified that the club often checked IDs and limited admission to patrons, though exact procedures at the time were not fully established.
- The circuit court denied a motion for mistrial after a detective’s cross-examination remark about ID checks; the court instructed the jury to disregard the statement, and Taylor was subsequently convicted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient for guilt beyond a reasonable doubt | Taylor argues eyewitness unreliability, weak DNA, and lack of proof he was in club before murders. | Taylor contends identifications were inherently unreliable and DNA insufficient to prove guilt beyond reasonable doubt. | Evidence was sufficient to convict |
| Whether the trial court abused its discretion by denying a mistrial over ID-check testimony | The detective’s statement about ID checks was prejudicial hearsay warranting mistrial. | The testimony was admissible or curable; prejudice was not shown after curative measures. | No abuse; mistrial denied |
Key Cases Cited
- State v. Nash, 339 S.W.3d 500 (Mo. banc 2011) (standard for sufficiency: rational juror could convict)
- State v. Lopez-McCurdy, 266 S.W.3d 874 (Mo. banc 2011) (jury credibility and weighing testimony; deference to jury)
- State v. Letica, 356 S.W.3d 157 (Mo. banc 2011) (jury credibility and weighing conflicting testimony)
- State v. Newberry, 605 S.W.2d 117 (Mo. banc 1980) (credibility not a basis for acquittal when evidence conflicts)
- State v. Rockett, 87 S.W.3d 398 (Mo. App. 2002) (DNA evidence partial profiles may support guilt)
- State v. Abdelmalik, 273 S.W.3d 61 (Mo. App. 2008) (partial DNA profile can support conviction when not excluding defendant)
- State v. Harding, 323 S.W.3d 810 (Mo. App. 2010) (partial DNA profiles may be weighed by jury)
- State v. Ward, 242 S.W.3d 698 (Mo. banc 2008) (mistrial review; prejudice standard)
- State v. Norris, 237 S.W.3d 640 (Mo. App. 2007) (discretion to grant mistrial and cure by curative instruction)
