William Taylor v. State of Indiana (mem. dec.)
06A01-1511-PC-1876
| Ind. Ct. App. | Oct 28, 2016Background
- William Taylor (defendant) was convicted in Boone County of two Class A child-molesting counts after the State amended a Class B charge to two Class A charges; he later received consecutive 40‑year sentences. He also pleaded guilty in Hendricks County to other counts resulting in a concurrent 25‑year sentence.
- Defense counsel Allen Lidy represented Taylor in both Boone and Hendricks County matters and pursued a strategy to obtain a global, concurrent plea to avoid a de facto life sentence for the then‑62‑year‑old client.
- In January 2011 the Boone County prosecutor had offered Taylor a guilty plea to the Class B child‑molesting charge for a 20‑year executed cap, but Lidy did not communicate that offer to Taylor before the plea deadline; the State then moved to amend to two Class A counts.
- At the post‑conviction hearing Lidy admitted he did not convey the Boone offer, testified his strategy was to avoid a B plea because it could harm negotiations in Hendricks County, and believed Taylor would not accept a B plea; Taylor testified he would have accepted the B plea to spare his family a trial.
- The post‑conviction court found Lidy’s failure to communicate the offer was deficient performance but concluded Taylor failed to prove prejudice — i.e., no reasonable probability he would have accepted the B plea given his objectives and the risk it posed to Hendricks County negotiations.
- The Court of Appeals affirmed, holding the post‑conviction court’s factual findings credible and that Taylor did not meet the Strickland prejudice prong for plea‑offer cases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Taylor received ineffective assistance because counsel failed to communicate a plea offer | Taylor: Lidy’s failure to inform him of Boone’s 20‑year B‑felony offer prejudiced him; he would have accepted the plea | State/Lidy: Although failing to communicate was deficient, Taylor would not have accepted the B plea because it conflicted with his goal to avoid admitting more than fondling and would harm Hendricks County negotiations | Court: Counsel’s failure was deficient but Taylor failed to show prejudice; post‑conviction court’s credibility findings affirmed |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes two‑prong ineffective assistance test: performance and prejudice)
- Woods v. State, 48 N.E.3d 374 (Ind. Ct. App. 2015) (counsel’s failure to communicate plea offer can be deficient performance)
- Dew v. State, 843 N.E.2d 556 (Ind. Ct. App. 2006) (prejudice shown where defendant would likely have accepted uncommunicated plea offer)
- McCary v. State, 761 N.E.2d 389 (Ind. 2002) (standard of review for post‑conviction factual findings)
- Hall v. State, 849 N.E.2d 466 (Ind. 2006) (appellate review limited to evidence supporting post‑conviction court’s judgment)
- Dewitt v. State, 755 N.E.2d 167 (Ind. 2001) (rigorous standard for post‑conviction relief on appeal)
- Jervis v. State, 28 N.E.3d 361 (Ind. Ct. App. 2015) (restates ineffective assistance review principles)