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302 Ga. 176
Ga.
2017
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Background

  • On December 28, 2012, Mark Antonio Taylor entered a car dealership, took a running truck, and was confronted by employee Charles Weaver. Surveillance video captured the encounter.
  • Taylor removed Weaver’s knife and cell phone at gunpoint, forced Weaver toward the building, shot him twice, and fled in the truck; Weaver later died from gunshot wounds.
  • Police tracked the stolen truck to an Atlanta apartment, recovered Weaver’s knife and the Hi-Point .45 that matched the murder weapon, and arrested Taylor, who repeatedly said “I did it” / “I killed him.”
  • Taylor was indicted for malice murder, multiple counts of felony murder and related felonies; convicted on all counts; sentenced to life without parole for malice murder with additional terms; felony-murder counts vacated as a matter of law.
  • On appeal and in a post-trial motion, Taylor raised (1) sufficiency of the evidence (Jackson claim), (2) ineffective assistance of counsel re: voir dire and juror strikes, (3) trial court error and ineffective assistance for admitting/citing evidence about an altercation with his girlfriend, and (4) alleged plain error in allowing an investigator’s opinion on self-defense.

Issues

Issue Plaintiff's Argument (Taylor) Defendant's Argument (State) Held
Sufficiency of the evidence Evidence insufficient to sustain convictions Surveillance, physical evidence, gun match, admissions support convictions Evidence sufficient under Jackson v. Virginia; convictions upheld
Ineffective assistance — voir dire and failure to strike jurors for cause Counsel’s voir dire was too brief and failed to strike biased jurors (Jurors 41, 52, 29) Counsel’s voir dire and strike decisions were strategic and within reasonable professional judgment No deficient performance; claim fails (no prejudice shown)
Admission of testimony re: fight with girlfriend (impeachment) Trial court erred in allowing cross-exam about the altercation; counsel ineffective for not objecting to prosecutor’s closing mention Cross-exam was proper impeachment because Taylor testified inconsistently about being expelled from the car; prosecutor’s closing reference harmless and no deficient performance Admission was within trial court’s discretion; evidence admissible for impeachment; counsel not ineffective
Investigator testimony about self-defense Plain error in allowing investigator to opine on self-defense Defense counsel elicited the topic on cross to introduce self-defense; cannot complain about error he invited No reviewable error—issue invited by defense; claim rejected

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
  • Pruitt v. State, 282 Ga. 30 (ineffective assistance two‑prong review and presumption of reasonable performance)
  • Ford v. State, 298 Ga. 560 (voir dire and trial strategy deference)
  • Parker v. State, 339 Ga. App. 285 (impeachment by contradiction and scope of cross‑examination)
  • Francis v. State, 266 Ga. 69 (defendant’s testimony may be disproved on cross‑examination)
  • Parks v. State, 300 Ga. 303 (scope of thorough cross‑examination)
  • Adkins v. State, 301 Ga. 153 (invited error doctrine)
  • Woods v. State, 271 Ga. 452 (no deficiency where challenged evidence was admissible)
Read the full case

Case Details

Case Name: Taylor v. State
Court Name: Supreme Court of Georgia
Date Published: Oct 2, 2017
Citations: 302 Ga. 176; 805 S.E.2d 851; S17A1033
Docket Number: S17A1033
Court Abbreviation: Ga.
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    Taylor v. State, 302 Ga. 176