Taylor v. Medeiros, 381 F. Supp. 3d 110

Background

Taylor was convicted in Massachusetts state court (July 2008) of second-degree murder for strangling Dominique Samuels and later burning her body; forensic evidence placed Taylor's DNA at the scene and witnesses testified to confessions and incriminating statements.
Trial evidence included cell‑phone records, DNA from a bloodstain in McCray’s room matching Taylor and the victim, and testimony that Taylor had discussed disposing/burning the body; Taylor argued McCray committed the murder.
During trial defense counsel alerted the judge that some jurors appeared to be sleeping; the judge addressed the jury collectively and declined individual voir dire; defense did not renew the issue at trial.
In closing the prosecutor made multiple forceful remarks: attacked the defense theory/counsel (including a "jury's oath" comment), referenced inconsistencies in Taylor’s statements (arguing only Taylor knew where he was), and stated his view of the forensic testimony ("it doesn't get any better than that"). The court gave curative instructions at the time and again in the final charge.
On direct and post‑conviction review the Massachusetts courts rejected claims about the sleeping jurors and prosecutorial misconduct; Taylor sought federal habeas relief under 28 U.S.C. § 2254 raising ineffective assistance (trial and appellate counsel) and prosecutorial‑misconduct/fifth‑amendment claims.
The federal court reviewed the claims under AEDPA standards and denied habeas relief, finding no unreasonable application of clearly established federal law or prejudice sufficient to overturn the conviction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance of trial counsel (sleeping jurors)	Taylor: counsel failed to secure voir dire of allegedly sleeping jurors, causing prejudice.	State: counsel raised the issue at trial; judge acted within discretion; no prejudicial error occurred.	Denied — claim procedurally defaulted on habeas; state courts reasonably found no trial error or prejudice.
Ineffective assistance of appellate counsel (failure to raise sleeping‑juror claim)	Taylor: appellate counsel was ineffective for not raising trial‑counsel ineffectiveness on direct appeal.	State: appellate counsel need not raise every non‑frivolous claim; no prejudice because trial court properly handled juror issue.	Denied — counsel’s omission not constitutionally deficient or, in any event, not prejudicial under Strickland.
Prosecutor’s attacks on defense theory and counsel (including "jury's oath")	Taylor: closing argument improperly impugned defense/counsel and violated due process.	State: remarks responsive to defense theory, isolated, curative instructions given, and weight of evidence was strong.	Denied — comments were neither so egregious nor prejudicial given context, instruction, and strong evidence.
Prosecutor’s comments about failure to testify and personal opinion	Taylor: prosecutor commented on his silence and offered personal opinion on evidence strength.	State: statements referred to prior inconsistent statements and lack of record evidence; any infirmity was isolated and cured by instruction; evidence overwhelming.	Denied — no Fifth Amendment violation nor prejudicial personal‑opinion misconduct under Darden/Young.

Key Cases Cited

Estelle v. McGuire, 502 U.S. 62 (1989) (federal habeas review limited to federal constitutional questions)
Williams v. Taylor, 529 U.S. 362 (2000) (AEDPA standard: contrary or unreasonable application of Supreme Court precedent)
Strickland v. Washington, 466 U.S. 668 (1984) (two‑part ineffective assistance test: deficient performance and prejudice)
Darden v. Wainwright, 477 U.S. 168 (1986) (prosecutorial remarks require reversal only if they "so infected the trial" as to deny due process)
Donnelly v. DeChristoforo, 416 U.S. 637 (1974) (isolated prosecutorial remarks in lengthy trial are insufficient for reversal absent prejudice)
United States v. Young, 470 U.S. 1 (1985) (contextual review of prosecutor's comments; not lightly overturn convictions)
Griffin v. California, 380 U.S. 609 (1965) (commenting on defendant's silence violates Fifth Amendment)
Harris v. New York, 401 U.S. 222 (1971) (prior inconsistent statements may be used to impeach defendant)
Jones v. Barnes, 463 U.S. 745 (1983) (appellate counsel not required to raise every nonfrivolous issue)
Harrington v. Richter, 562 U.S. 86 (2011) (Strickland prejudice requires more than speculative or conceivable difference in outcome)