TAYLOR v. STATE
419 P.3d 265
| Okla. Crim. App. | 2018Background
- Edward Anthony Taylor was convicted by a jury in Caddo County for possession with intent to distribute; sentenced to 15 years and a $20,000 fine.
- After charges and appointment/appearance of defense counsel, a deputy sheriff interviewed Taylor while he was in custody.
- Taylor signed a Miranda Advice of Rights form and affirmatively waived the right to have counsel present before speaking; he made statements during that interview.
- Taylor moved to suppress the statements and to dismiss the charge, alleging violation of his Fifth and Sixth Amendment right to counsel under the then-governing Michigan v. Jackson rule.
- The trial court suppressed the custodial statement (parties believed Jackson controlled) but denied dismissal; no interrogation evidence was used at trial.
- On appeal, the Court concluded Montejo v. Louisiana overruled Jackson’s prophylactic rule; because Taylor knowingly waived rights after Miranda warnings, there was no constitutional violation and dismissal was not required; ineffective-assistance claim also failed for lack of prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether dismissal was required because police interrogated Taylor after counsel appeared | Taylor: police-initiated interrogation after counsel appeared violated Sixth Amendment rights (relying on Jackson), warranting dismissal | State: no violation because Taylor knowingly and voluntarily waived rights after Miranda; suppression (not dismissal) is appropriate remedy | Denied — no violation under current law (Montejo); waiver was valid; suppression already granted, so dismissal not required |
| Whether statements obtained were admissible | Taylor: statements were obtained in violation of right to counsel and influenced plea bargaining, so should be excluded and case dismissed | State: waiver after Miranda made statements constitutionally obtained; even if error, suppression cures it | Court: waiver was knowing and voluntary; statement admissible under constitutional standards, though suppressed below based on mistaken view of Jackson |
| Whether defense counsel’s conduct amounted to ineffective assistance | Taylor: counsel’s behavior and failure to present arguments effectively caused adverse rulings and prejudice | State: even if counsel erred, Taylor suffered no prejudice because no constitutional violation and statement suppressed | Denied — no prejudice shown under Strickland; outcome would not likely differ |
| Whether precedents requiring automatic suppression/dismissal when counsel present remain valid | Taylor: relied on pre-Montejo Oklahoma cases applying Jackson rule | State: Montejo overruled Jackson’s bright-line rule; Miranda/Edwards/Minnick and voluntariness principles control | Court: overruled state cases to extent inconsistent with Montejo; Jackson prophylactic rule no longer applies |
Key Cases Cited
- Michigan v. Jackson, 475 U.S. 625 (1986) (formerly created bright-line rule barring police-initiated interrogation after assertion of Sixth Amendment right at arraignment)
- Montejo v. Louisiana, 556 U.S. 778 (2009) (overruled Jackson; waiver after Miranda can be valid absent invocation)
- Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required for custodial interrogation; waiver must be knowing and voluntary)
- Edwards v. Arizona, 451 U.S. 477 (1981) (once Miranda rights invoked, further interrogation generally forbidden until counsel is present)
- Minnick v. Mississippi, 498 U.S. 146 (1990) (no subsequent interrogation after request for counsel until counsel present)
- Malloy v. Hogan, 378 U.S. 1 (1964) (Fourteenth Amendment requires voluntariness for statements introduced against defendant)
- Patterson v. Illinois, 487 U.S. 285 (1988) (Miranda warnings adequately inform defendant of Sixth Amendment right consequences so waiver can be valid)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel: deficient performance and prejudice)