Background

• Taylor was convicted of capital murder for the 2007 Guerrero killing during an aggravated robbery; sentenced to life without parole plus 10 years for firearm enhancement.
• Police chase: Taylor fled from officers; four officers identified him from a photo and testified he dropped a jacket with the murder weapon.
• Roberson’s letters: pretrial letters from Roberson to Moore were introduced; Clouette used a boot‑camp letter to impeach Roberson, but Roberson denied writing it and denied a deal.
• Rule 37 petition: Taylor claimed ineffective assistance for (i) improper impeachment of Roberson with the letters and (ii) failure to call Moore or a medical doctor to prove incapacity.
• Rule 37 court’s analysis: found no prejudice under Strickland; jury was aware of Taylor’s impeachment theory; Swopes testified to injuries; Kebler’s testimony would have been cumulative and not refute officers’ observed actions.
• Appeal outcome: Arkansas Supreme Court affirmed the circuit court’s denial of postconviction relief.

Issues

Key Cases Cited

• Springs v. State, 387 S.W.3d 143 (Ark. 2012) (standard for reviewing 37 petition; clear error)
• Williams v. State, 251 S.W.3d 290 (Ark. 2007) (two-prong Strickland test)
• Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes standard for ineffective assistance)
• Sparkman v. State, 281 S.W.3d 277 (Ark. 2008) (two-prong Strickland application on appeal)
• Wicoff v. State, 900 S.W.2d 187 (Ark. 1995) (prejudice analysis when prosecution case is strong; impeachment context)
• Gaye v. State, 307 S.W.3d 1 (Ark. 2009) (impeachment impact when other witnesses at scene; not prejudicial)
• Helton v. State, 924 S.W.2d 239 (Ark. 1996) (cumulative evidence principle)
• Russell v. State, 789 S.W.2d 720 (Ark. 1990) (prejudice from missing witness in murder case)
• Hart v. State, 238 S.W.3d 24 (Ark. 2006) (contextual prejudice standard)