Taylor v. State
2011 Ark. 10
| Ark. | 2011Background
- Appellant charged by amended information (June 27, 2008) with capital murder in Odilon Guerrero's death; life imprisonment sought.
- Trial held March 2, 2010; key testimony from accomplice Tyeiska Roberson alleging appellant's involvement and possession of the murder weapon.
- Defense moved for directed verdict, arguing lack of corroboration beyond Roberson's testimony; court found Roberson corroborated by other evidence, including weapon possession.
- Other testimony linked appellant to the crime: Guerrero nephew Gregorio Guerrero; police officers testified to a chase and identification of weapon; jacket containing the murder weapon recovered.
- Jurisdiction and sentencing: conviction affirmed; life without parole plus a firearm enhancement of ten years, to run consecutively; Rule 4-3(i) noncompliance noted but not prejudicial.
- Appellant timely appealed; issue raised regarding sufficiency of corroboration for accomplice Roberson's testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there sufficient corroboration of Roberson's testimony? | Roberson's testimony alone connected appellant to the murder. | Corroboration insufficient to connect appellant to the crime beyond Roberson's testimony. | Yes; substantial corroboration exists that independently connects appellant to the crime. |
| Can flight from police serve as corroboration of guilt? | Flight evidence corroborates Roberson and other evidence of guilt. | Flight alone is insufficient without independent corroboration. | Flight may be considered as corroboration in conjunction with other evidence. |
| Did failure to abstract adverse rulings under Rule 4-3(i) prejudice the defense? | Rule 4-3(i) noncompliance undermines appellate review. | Noncompliance is acknowledged but does not affect outcome given record review. | Noncompliance acknowledged; no prejudicial error found in the record. |
Key Cases Cited
- Boldin v. State, 283 S.W.3d 565 (Ark. 2008) (standard for directed verdict and sufficiency of evidence)
- Wertz v. State, 287 S.W.3d 528 (Ark. 2008) (corroboration must be substantial and connect the accused to the crime)
- Stephenson v. State, 282 S.W.3d 772 (Ark. 2008) (accomplice corroboration must have substantive corroborating facts)
- Bennett v. State, 679 S.W.2d 202 (Ark. 1984) (corroboration for accomplice testimony may permit inference of truth as to all facts)
- Strong v. State, 277 S.W.3d 159 (Ark. 2008) (flight as a corroborating factor in assessing probable guilt)