State v. Taylor, 731 S.E.2d 596

Taylor, a church pastor, was convicted of second-degree criminal sexual conduct with a minor and kidnapping for raping a then-11-year-old Victim in 1998 and later raping Victim at Taylor's home in 1999.
Victim disclosed the two rapes years later; Taylor pled guilty to the 1999 offense in Georgetown County and was sentenced to eight years, suspended on probation.
In 2006 Taylor was indicted for the 1998 rape and kidnapping and the State sought a sentence of life without parole under §17-25-45; he was convicted on both counts and sentenced to LWOP.
Taylor challenged the trial court on Batson, admissibility of his prior conviction evidence, a directed-verdict issue, and LWOP sentencing; the appellate court affirmed.
The appellate decision discusses Batson compliance, Rule 404(b) common-scheme analysis for the 1998 and 1999 rapes, venue considerations for the 1998 rape, and preservation requirements for LWOP-related arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Batson challenge to Juror 146 strike	Taylor claims the strike was racially motivated	State argues neutral reasons supported the strike	Trial court’s Batson finding affirmed; pretext shown by seating Juror 138
Admission of 1999 rape as common scheme evidence	Evidence should be excluded under Rule 404(b) due to dissimilarity	Evidence shows close similarity and supports a common scheme	Admissible; similarities outweigh prejudice under Wallace factors
Venue and directed verdict for 1998 rape	State failed to prove Williamsburg County venue	Slight evidence suffices to infer venue	Sufficient venue evidence; denial of directed verdict upheld
Life without parole based on predicate offenses	Two rapes should be treated as one continuous offense under §17-25-50	Issue preserved for review; no continuous-event finding made	Not preserved for review; waiver/preservation failure

State v. Hicks, 330 S.C. 207, 499 S.E.2d 209 (1998) (prohibition on race-based jury strikes; Batson framework)
Batson v. Kentucky, 476 U.S. 79, 90 L. Ed. 2d 69 (1986) (U.S. 1986) (prohibits striking on race in jury selection)
State v. Haigler, 334 S.C. 623, 515 S.E.2d 88 (1999) (requires Batson hearing when cognizable racial group is struck)
State v. Edwards, 384 S.C. 504, 682 S.E.2d 820 (2009) (totality-of-the-circumstances review for Batson; deference to trial court findings)
State v. Wallace, 384 S.C. 428, 683 S.E.2d 275 (2009) (factors for determining common scheme or plan in 404(b) claims in sexual offenses)
State v. Clasby, 385 S.C. 148, 682 S.E.2d 892 (2009) (continuing pattern of abuse supports common scheme under 404(b))
State v. Mathis, 359 S.C. 450, 597 S.E.2d 872 (Ct. App. 2004) (probative value of prior assaults outweighs prejudice in similar-sex-crimes context)
State v. Ford, 334 S.C. 59, 512 S.E.2d 500 (1999) (legitimate to strike jurors because of employment; race-neutral explanations evaluated)