Taylor v. State
811 S.E.2d 286
Ga.2018Background
- Taylor was a live-in caretaker for Theodore Crew; neighbors heard a late-night scuffle and Crew was found dead with numerous blunt and sharp-force injuries; medical examiner ruled homicide.
- Less blood than expected and cleaning/bleach indicators; a brown grocery bag with bloody items and a box cutter were found nearby.
- Taylor initially told police she spent the night at her mother’s, then asked for a lawyer during police questioning.
- Two days later, while in jail, Sergeant March (a corrections officer) spoke with Taylor during an unprompted cigarette break; Taylor spontaneously said she had "cut him" but did not kill him.
- Taylor’s videotaped interrogation (pre‑lawyer invocation) included officers proposing scenarios and asserting belief in her culpability; the tape was admitted at trial.
- Jury acquitted Taylor of malice murder but convicted her of felony murder (aggravated assault predicate); she was sentenced to life without parole and appealed, raising evidentiary and Confrontation Clause claims.
Issues
| Issue | Taylor's Argument | State's Argument | Held |
|---|---|---|---|
| Admissibility of videotaped interrogation (police statements expressing opinions/scenarios) | Statements expressing officers' opinions and suggested scenarios were improper character/guilt evidence and prejudicial | Statements were interrogation tactics; any error not preserved so plain‑error review applies; and statements matched Taylor’s later confession so did not affect outcome | No plain error; tape admissible; confession and other evidence defeated claim |
| Alleged involuntary/confession after right to counsel invoked (Sergeant March jail statements) | Sergeant March’s conduct was the functional equivalent of interrogation after counsel invoked, so admission violated Miranda/Edwards | Exchange was an incentive to get Taylor to eat, not calculated to elicit incriminating responses; Taylor’s statement was spontaneous/reinitiation | Admission proper; not interrogation; spontaneous admission admissible despite prior request for counsel |
| Mistrial request for neighbor testimony implying criminal history | Neighbor’s remark inferred Taylor had a criminal background and improperly placed character evidence before jury | Testimony merely conveyed witness’s lack of knowledge of Taylor’s background and was incidental to explaining his reluctance to call police | Denial of mistrial affirmed; no improper character evidence or abuse of discretion |
| Confrontation Clause / medical examiner testifying to toxicology results performed by another | Taylor argued admission of toxicology results via ME violated right to confront the analyst | ME drew blood, ordered test, relied on results to form opinion; results were used to support opinion, not admitted as lab report | Admissible: results were not offered as the lab report; ME’s testimony as expert relying on test was permissible |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (jury sufficiency standard)
- Gates v. State, 298 Ga. 324 (plain‑error four‑part test)
- Bullcoming v. New Mexico, 564 U.S. 647 (Confrontation Clause and lab analysts)
- Disharoon v. State, 291 Ga. 45 (testifying witness with significant connection to test may substitute for analyst)
- Naji v. State, 300 Ga. 659 (distinguishing lab report admission from expert reliance on test results)
- Miranda v. Arizona, 384 U.S. 436 (custodial interrogation warnings)
- Edwards v. Arizona, 451 U.S. 477 (right to counsel: reinitiation and waiver principles)
- Rhode Island v. Innis, 446 U.S. 291 (functional equivalent of interrogation standard)
- State v. Brown, 287 Ga. 473 (spontaneous admissions and duty to listen)