United States v. Michael Taylor
2012 U.S. App. LEXIS 24629
| 7th Cir. | 2012Background
- Taylor, a felon, was charged with unlawful possession of a firearm after a prior felony and went on a shooting spree in Aurora, Illinois over two days in 2009.
- Before trial, Taylor moved to exclude two recovered guns (a revolver and a Bersa) linked to two co-arrested individuals; the district court admitted them.
- Evidence connected Taylor to the Beretta via shell casings, GSR on his hand, and bullets from the Beretta found at multiple locations.
- Starks testified that Taylor fired the Beretta on December 1; officers located the other firearms near the co-arrested individuals, corroborating his account.
- At sentencing, the district court imposed 480 months based on an upward variance due to Taylor’s violent history and offense conduct, well above the guideline range.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of 404(b) evidence | Taylor argues the revolver and Bersa were improper 404(b) evidence. | Government contends evidence shows co-defendants’ ownership and supports guilt; argues 403 balancing. | District court did not abuse discretion; evidence probative and not unduly prejudicial. |
| Sufficiency of the evidence for possession | Taylor contends evidence fails to prove possession beyond reasonable doubt. | Government presents direct and corroborating evidence tying Taylor to Beretta and GSR. | Sufficient evidence supported the jury verdict. |
| Reasonableness of above-guidelines sentence | Taylor challenges 480-month sentence as substantively unreasonable. | Court found substantial justification under 3553(a) for an upward variance based on history and conduct. | Sentence affirmed as reasonable under abuse-of-discretion review. |
Key Cases Cited
- United States v. Boros, 668 F.3d 901 (7th Cir. 2012) (broad discretion in evidentiary rulings for Rule 404(b) and 403)
- United States v. Hall, 165 F.3d 1095 (7th Cir. 1999) (abuse-of-discretion standard for evidentiary rulings)
- Jackson v. Virginia, 443 U.S. 307 (1980) (standard for sufficiency of evidence review)
- United States v. Hodges, 315 F.3d 794 (7th Cir. 2003) (elements for felon-in-possession conviction)
- United States v. Bradley, 675 F.3d 1021 (7th Cir. 2012) (sufficiency and reasonableness standards; above-guidelines scrutiny)