Taylor v. DeMatteis, 1:11-cv-01251

Background

In March 2000 Theresa Williams was found murdered; Milton Taylor was identified, arrested, and a handwritten confession found during an inventory search formed a central piece of evidence. Taylor was convicted of first‑degree murder and sentenced to death; conviction and sentence were affirmed on direct appeal.
Taylor pursued a Rule 61 postconviction proceeding (first Rule 61) in 2006–2011; the Superior Court held lengthy evidentiary hearings and denied relief; the Delaware Supreme Court affirmed in 2011.
Taylor filed federal habeas in 2012, stayed to exhaust additional claims in state court; after Rauf (Del. 2016) vacated Delaware’s death‑penalty procedure, Taylor’s death sentence was vacated and he was resentenced in 2017 to life without parole under 11 Del. C. § 4209(a).
Taylor filed a second Rule 61 motion (post‑2014 Rule 61 amendments); the Superior Court dismissed it as a second or subsequent motion under amended Rule 61(d)(2), and the Delaware Supreme Court affirmed in 2019.
In federal proceedings Taylor asserted (major claims): ineffective assistance of trial counsel for not pursuing an extreme emotional distress (EED) defense and several other trial errors; ineffective assistance of appellate/postconviction counsel; cumulative error; and that resentencing under § 4209 violated Eighth and Fourteenth Amendment rights. The district court denied the § 2254 petition.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Trial counsel ineffective for not presenting EED defense	Taylor: counsel failed to investigate/retain experts and would have shown EED and mitigators sufficient to avoid first‑degree murder or death.	State: counsel retained multiple mental‑health experts, investigated records and witnesses, and reasonably declined to pursue an EED defense; new experts rely on uncorroborated statements.	Denied — state courts reasonably applied Strickland; investigation and strategy were not deficient and Taylor fails Strickland prejudice.
2) Adequacy of Delaware Superior Court Criminal Rule 61 (post‑2014) as an independent, adequate state procedural bar	Taylor: he lacked fair notice in 2006 that the 2014 amendments would narrow exceptions to successive petitions, so post‑2014 Rule 61 is not adequate to bar federal review.	State: Delaware long barred successive petitions; the change narrowed exceptions but gave fair notice that failure to include claims in the first Rule 61 risks default.	Denied — the court held the 2014 Rule 61 successive‑motion bar was firmly established and adequate as applied; Taylor had fair notice to include all claims in his first Rule 61.
3) Sentencing: whether resentencing under § 4209 to mandatory life without parole violated Eighth or Fourteenth Amendments or state separation‑of‑powers	Taylor: Rauf rendered § 4209 void so resentencing should have been under § 4205; mandatory LWOP is cruel and unusual and deprived him of notice affecting trial strategy.	State: sentencing/interpretation of Delaware statutes is a matter of state law; imposing LWOP under § 4209 is constitutional and within legislature's prerogative.	Denied — state‑law sentencing claims not cognizable on habeas; Eighth and Due Process claims rejected as not contrary to clearly established federal law.
4) Other trial errors (failure to retain forensic pathologist; failure to object to pregnancy evidence; suppression motion inadequacy; biased jury or juror taint; prosecutorial misconduct) and ineffective assistance of appellate/postconviction counsel	Taylor: these unraised or defaulted claims were meritorious or excused by ineffective postconviction counsel (Martinez) or would cumulatively warrant relief.	State: these claims were procedurally defaulted under Rule 61(d)(2); Martinez does not excuse non‑IATC claims and Taylor failed to show initial postconviction counsel was objectively unreasonable.	Denied — claims One(B)–(F), Two, Three were held procedurally barred; Martinez inapplicable or not satisfied; Taylor fails to show prejudice or miscarriage of justice (no new reliable proof of factual innocence).

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong ineffective assistance of counsel standard)
Coleman v. Thompson, 501 U.S. 722 (1991) (procedural default doctrine; independent and adequate state grounds)
Martinez v. Ryan, 566 U.S. 1 (2012) (narrowly permits excuse of procedural default where initial postconviction counsel was ineffective for failing to raise substantial IATC claims)
Wainwright v. Witt, 469 U.S. 412 (1985) (standard for excluding jurors for views on capital punishment)
Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA deference; "doubly deferential" review of Strickland on habeas)
Taylor v. State, 822 A.2d 1052 (Del. 2003) (Delaware Supreme Court decision affirming conviction and discussing confession and evidence)
Rauf v. State, 145 A.3d 430 (Del. 2016) (Delaware Supreme Court: Hurst‑type Sixth Amendment defect in § 4209 capital scheme)
Powell v. State, 153 A.3d 69 (Del. 2016) (Rauf applied retroactively to final sentences)
Purnell v. State, 254 A.3d 1053 (Del. 2021) (application of actual‑innocence exception under amended Rule 61)
Zebroski v. State, 179 A.3d 855 (Del. 2018) (life‑without‑parole alternative valid after Rauf)
Rummel v. Estelle, 445 U.S. 263 (1980) (proportionality principle and deference to legislative sentencing choices)
Brecht v. Abrahamson, 507 U.S. 619 (1993) (harmless‑error standard for habeas relief)
Yarborough v. Gentry, 540 U.S. 1 (2003) (presumption that counsel’s tactical choices are reasonable)