Taylor v. State
2012 UT 5
Utah2012Background
- Taylor pled guilty to two capital murders; penalty phase resulted in a death sentence.
- Rule 238B hearing on ineffective assistance of trial counsel occurred in 1995 and was affirmed on appeal in Taylor I; subsequent Taylor II proceedings addressed ineffective assistance of appellate counsel.
- Taylor filed a successive petition for post-conviction relief in November 2007; district court granted the State’s dismissal motion in August 2009.
- The district court held all thirty claims procedurally barred under the PCRA for having been raised or could have been raised in a prior proceeding, and none fit PCRA exceptions.
- Taylor appeals challenging twelve of the original thirty claims, including venue, voir dire, prosecutorial conduct, exculpatory evidence, and proportionality of the death sentence.
- Court analyzes both PCRA procedural bar and exceptions, ultimately affirming dismissal and finding no applicable common-law or statutory exceptions to the bar.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are Taylor’s claims procedurally barred under the PCRA? | Taylor argues the claims rely on newly discovered facts not known earlier. | State argues claims were raised or could have been raised earlier and do not satisfy exceptions. | Procedurally barred; not saved by exceptions. |
| Do any common-law or statutory exceptions apply to save the claims? | Taylor asserts good-cause and ineffective-assistance exceptions apply. | State contends exceptions do not apply and earlier proceedings foreclose relief. | No applicable exceptions found. |
| Did newly discovered evidence suffice to overcome the procedural bar? | Taylor relies on post-petition discoveries to trigger exceptions. | Notes and evidence are cumulative or do not raise reasonable doubt. | Newly discovered-evidence exception not satisfied. |
| Was there juror or voir dire error deserving relief? | Claims involve blood atonement doctrine and voir dire questions. | Previous Taylor II analysis already addressed bias; no new bias shown. | Procedurally barred; no new constitutional error established. |
Key Cases Cited
- Taylor II v. State, 2007 UT 12 (Utah 2007) (post-conviction relief; ineffective assistance issues previously adjudicated)
- Gardner v. State (Gardner II), 2010 UT 46 (Utah 2010) (amendments to PCRA; codified exceptions; not retroactive here)
- Gardner v. Galetka (Gardner I), 2004 UT 42 (Utah 2004) (recognition of five common-law exceptions retained for review)
- Medel v. State, 2008 UT 32 (Utah 2008) (newly discovered evidence requires reasonable doubt to merit relief)
- State v. DeMille, 756 P.2d 81 (Utah 1988) (juror deliberation and extrinsic evidence considerations under rule 606(b))
- Rhinehart v. State, 2007 UT 61 (Utah 2007) (plea voluntariness and its effect on relief)