Taylor v. State
382 S.W.3d 78
| Mo. | 2012Background
- Movant Leonard Taylor was convicted of four counts of first-degree murder and four related death sentences, and his direct appeal was affirmed.
- Taylor filed a pro se Rule 29.15 post-conviction motion alleging ineffective assistance of counsel based on investigation and handling of Charter landline and Sprint records.
- An evidentiary hearing was held on some claims; the motion court denied a hearing on others and overruled the motion in part.
- The motion court concluded there was overwhelming evidence of Taylor's guilt, undermining Strickland prejudice.
- Taylor’s brother provided statements and evidence, including a taped interview, linking Taylor to the killings; corroborating physical and documentary evidence was presented at trial.
- On appeal, the Missouri Supreme Court affirmed the motion court, finding no reasonable probability that the outcome would have differed but-for counsel's alleged errors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Taylor proved prejudice under Strickland | Taylor argues counsel's investigation prejudiced trial results | State contends overwhelming evidence shows guilt regardless of counsel errors | No prejudice; overwhelming evidence defeats Strickland prejudice |
| Whether due process was violated by alleged false testimony | Taylor claims Charter testimony was false and used to convict | State argues burden and proof require more than false testimony; record supports guilt | No due process violation; false testimony burden not met |
| Whether the motion court erred in dismissing other ineffective-assistance claims | Taylor asserts additional trial counsel failings merit relief | State asserts lack of prejudice or non-meritorious objections | No error; claims fail under Strickland analysis |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (establishes two-prong test for ineffective assistance)
- State v. Statler, 383 S.W.2d 534 (Mo.1964) (false-testimony due-process framework)
- Goodwin v. State, 191 S.W.3d 20 (Mo. banc 2006) (standard for reviewing post-conviction denials)
- Moss v. State, 10 S.W.3d 508 (Mo. banc 2000) (clear-error review in post-conviction context)
- State v. Blankenship, 830 S.W.2d 1 (Mo. banc 1992) (preserves standard for prejudice requirements in Rule 29.15)
- State v. Taylor, 298 S.W.3d 482 (Mo. banc 2009) (definitive recitation of underlying facts on appeal)