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State v. Taylor
504 S.W.3d 116
Mo. Ct. App.
2016
Read the full case

Background

  • Defendant Tyrone Taylor was tried by bench trial for second-degree murder and armed criminal action for the shooting death of Antoine Bryant; the court convicted and sentenced Taylor to 25 years.
  • Eyewitness Louquine Rollins testified she saw Taylor emerge from an alley and shoot Bryant multiple times while Bryant rode a moped with both hands on the grips; Rollins was confident Taylor was the shooter.
  • Eyewitness Alberto Garcia (called by defense) testified he saw "something darker" in Bryant’s hand and opined there may have been two guns, but did not tell police about the object and was less certain about details.
  • Taylor testified he acted in self-defense, claiming Bryant reached for a gun and he fired about five times after retreating into an alley.
  • Bryant’s mother gave emotional testimony about identifying her son at the hospital and fainting; Taylor objected as prejudicial.
  • Ballistics and physical evidence did not definitively identify shooter location or whether one or two guns fired; medical examiner testified Bryant was struck by multiple bullets, one lodging in his chest.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of evidence to convict of second-degree murder and armed criminal action State: Rollins’ testimony that Taylor knowingly shot Bryant supports conviction. Taylor: Only Rollins supported conviction; her testimony conflicted with other witnesses and physical evidence, so evidence insufficient. Court: Single witness (Rollins) sufficient; trial court credited her. Evidence legally sufficient.
Admissibility of victim’s mother’s hospital testimony State: Testimony is admissible and not outcome-determinative. Taylor: Testimony was irrelevant, highly prejudicial, and should have been excluded. Court: Even if erroneous, in judge-tried case no showing it affected outcome; no outcome-determinative prejudice.
Prosecutor’s closing comment about needing both hands to operate a moped State: Comment was a reasonable inference from testimony (Rollins and Garcia) and responds to defense theory. Taylor: Comment asserted facts not in evidence and should have been struck. Court: Comment drawn from trial testimony and reasonable inference; no plain error.
Plain-error review for unpreserved closing argument objection N/A Taylor: Failure to strike was plain error requiring reversal. Court: High threshold for plain error; defendant failed to show manifest injustice.

Key Cases Cited

  • State v. Pate, 469 S.W.3d 904 (Mo. App. E.D.) (single witness sufficient to support conviction)
  • State v. Holman, 230 S.W.3d 77 (Mo. App. S.D.) (credibility and weight of testimony are for the fact-finder)
  • State v. Crites, 400 S.W.3d 828 (Mo. App. S.D.) (presumption that judge not influenced by inadmissible evidence in bench trial)
  • State v. Houston, 467 S.W.3d 894 (Mo. App. E.D.) (prejudice requires evidence more likely than not affected outcome)
  • State v. Sanchez, 186 S.W.3d 260 (Mo. banc) (plain-error standard for unpreserved objections)
  • State v. Edwards, 116 S.W.3d 511 (Mo. banc) (closing argument limited to evidence and reasonable inferences)
Read the full case

Case Details

Case Name: State v. Taylor
Court Name: Missouri Court of Appeals
Date Published: Aug 23, 2016
Citation: 504 S.W.3d 116
Docket Number: No. ED 103520
Court Abbreviation: Mo. Ct. App.