Taylor v. State, 306 Ga. 277

In June 2009 Dorsey was shot and killed during a drug transaction; Kelvin Sheats drove Dorsey to the scene and witnessed events but initially could not identify the shooter.
Two eyewitnesses (Sheats and Brandon Jones) later identified Davious Taylor (nicknamed "Foot") as the taller, light-skinned man who shot Dorsey; Jones identified Taylor in 2009/2013 and testified Taylor threatened him in jail.
The homicide investigation produced photographic lineups in 2009 and renewed investigation in 2013; Sheats identified Taylor after reviewing multiple photos in 2013.
Taylor was indicted in 2014 and, after a 2016 joint trial with co-defendant Banks, was convicted of malice murder and possession of a weapon during the commission of a crime; sentenced to life without parole plus five years.
The State sought to admit extrinsic-act evidence under OCGA §24-4-404(b) (a 2011 aggravated assault/weapon incident and a 2008 drug incident); the court struck the 2008 evidence but admitted the 2011 incident.
On appeal Taylor challenged sufficiency of the evidence, admission of 404(b) evidence, several jury-charge issues (accomplice, statute-of-limitations, 404(b) usage), grant of State’s motion in limine excluding his self-serving statements, and alleged ineffective assistance of trial counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence (murder & weapon)	Evidence did not prove Taylor was shooter beyond reasonable doubt	Eyewitness IDs (Sheats, Jones), jail threats, phone records and corroboration support conviction	Affirmed: Evidence sufficient when viewed favorably to jury (Jackson standard)
Admission of 404(b) extrinsic-act evidence (2011 incident)	Admission was erroneous and unfairly prejudicial	Evidence relevant to motive/intent/knowledge; minimal use at trial; harmless if erroneous	Even assuming error, admission was harmless beyond reasonable doubt; conviction stands
Jury instructions (accomplice testimony; statute of limitations; 404(b) use)	Court should have charged accomplice rule and sua sponte on statute of limitations; 404(b) charge wording improper	No accomplice charge warranted (Sheats not an accomplice); indictment alleged tolling; 404(b) language follows pattern instruction	No plain error: accomplice charge unwarranted; statute-of-limitations allegation in indictment and general burden instruction sufficient; 404(b) instruction appropriate
Ineffective assistance of counsel	Counsel failed to object to in limine ruling, omitted charges, failed demurrer/request on statute of limitations	Many objections would have lacked merit; indictment not defective; jury properly instructed; no reasonable probability of different outcome	Denied: performance not shown deficient or prejudice not established under Strickland

Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
Strickland v. Washington, 466 U.S. 668 (two-pronged test for ineffective assistance of counsel)
State v. Jones, 297 Ga. 156 (trial court review standard for admitting other-acts evidence)
Booth v. State, 301 Ga. 678 (applying three-prong test for Rule 404(b) admissibility)
Manning v. State, 303 Ga. 723 (application of evidence-code/Rule 404(b) principles)
United States v. Jernigan, 341 F.3d 1273 (Eleventh Circuit guidance on timing of other-acts evidence)
Smith v. State, 299 Ga. 424 (harmless-error standard for nonconstitutional errors)