State v. Taylor
2022 Ohio 614
Ohio Ct. App.2022Background
- Victim Daniel Donlan lived in Lakewood; neighbor Gary Taylor repeatedly asked Donlan for money over years. Donlan kept notebooks documenting loans (≈$25,000 over 2½ years) and had recently written he would give Taylor "no more."
- On Jan. 27, 2018, Donlan withdrew cash, was last texted that evening, and was murdered in his basement by blunt-force trauma between ~5:00–10:00 p.m.; blood, shoe/boot impressions, a circular saw and a brick were found nearby.
- Taylor lived across the street; police found Taylor’s DNA on Donlan’s shirt and right pants pockets. No cash was found on Donlan. Taylor called 911 two days later claiming he last saw Donlan earlier than the notebooks and receipts indicated.
- Ten days before the murder, officers recorded Taylor (in boots) admitting a severe crack addiction and that he would "go to any length" for money; police later did not recover those boots in searches of Taylor’s apartment.
- Taylor bought $100 of crack from his son around 10:00 p.m. on Jan. 27 (an unusually large purchase for him). He was tried by jury, convicted of aggravated murder (merged counts) and sentenced to life with parole possible after 25 years; this appeal followed.
Issues
| Issue | State's Argument | Taylor's Argument | Held |
|---|---|---|---|
| 1. Evidence that boots Taylor wore Jan. 17 were not recovered (inference stacking) | Absence supports inference Taylor disposed of bloody boots after murder | Admission stacks inference upon inference and was therefore improper | Court: admission was erroneous but harmless — other strong circumstantial evidence supported guilt |
| 2. Admission of Jan. 17 bodycam statements about crack addiction (Evid.R.404(B)) | Statements showed motive (need for money to support addiction) and were highly probative | Statements were other-acts evidence offered to show bad character | Court: admissible for motive; probative value outweighed prejudice |
| 3. Suppression of Jan. 17 statements (Miranda) | Statements were voluntary and noncustodial; Miranda not required | Taylor was "in custody" and should have been Mirandized | Court: encounter was noncustodial (no restraint/coercion); denial of suppression affirmed |
| 4. Sufficiency of evidence for aggravated murder | DNA on clothing/pockets, victim notebooks, time window, missing cash, $100 cocaine purchase, elimination of other suspects | DNA could reflect earlier lawful contact; evidence was circumstantial and insufficient | Court: viewing evidence favorably to prosecution, rational juror could find guilt beyond reasonable doubt — sufficiency upheld |
| 5. Manifest weight of the evidence | Combined circumstantial evidence supports verdict | DNA not dispositive; unknown contributor could be killer; verdict against weight | Court: not a manifest miscarriage of justice; conviction affirmed |
Key Cases Cited
- State v. Cowans, 87 Ohio St.3d 68, 717 N.E.2d 298 (rule on impermissible stacking of inferences)
- Hurt v. Charles J. Rogers Transp. Co., 164 Ohio St. 329, 130 N.E.2d 820 (prohibits drawing an inference solely from another inference)
- Motorists Mut. Ins. Co. v. Hamilton Twp. Trustees, 28 Ohio St.3d 13, 502 N.E.2d 204 (limits application of the inference-stacking rule)
- McDougall v. Glenn Cartage Co., 169 Ohio St. 522, 160 N.E.2d 266 (multiple inferences from same facts permissible)
- Donaldson v. N. Trading Co., 82 Ohio App.3d 476, 612 N.E.2d 754 (inference-stacking rule must be strictly limited)
- State v. Perez, 124 Ohio St.3d 122, 920 N.E.2d 104 (standard of review and trial-court discretion on other-acts evidence)
- State v. Diar, 120 Ohio St.3d 460, 900 N.E.2d 565 (admission of other-acts evidence discussion)
- State v. Williams, 134 Ohio St.3d 521, 983 N.E.2d 1277 (Evid.R.404(B) framework)
- State v. Hartman, 161 Ohio St.3d 214, 161 N.E.3d 651 (probative value vs. unfair prejudice analysis)
- Miranda v. Arizona, 384 U.S. 436 (Miranda custodial-interrogation warnings)
- Yarborough v. Alvarado, 541 U.S. 652 (custody test: would a reasonable person feel free to leave)
- California v. Beheler, 463 U.S. 1121 (custody relates to restraint associated with formal arrest)
- State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (sufficiency standard)
- State v. Treesh, 90 Ohio St.3d 460, 739 N.E.2d 749 (circumstantial evidence has same weight as direct evidence)