Criminal: Juvenile Offender — Timothy Taylor v. Com. of Kentucky (SC 12/18/2008)

Timothy Taylor v. Com. of Kentucky (259)
Criminal:  Juvenile Offender
Questions Presented: 
Juvenile offender – Murder – 25 year sentence. 
OPINION by Abramson
Jefferson – Judge Montano
Date Rendered: 12/18/2008

Opinion by Justice Abramson. All sitting; all concur. The Supreme Court affirms a 25-year sentence for defendant convicted of murder. Taylor, who was 17 year old when the crime was committed, appealed the trial court’s refusal to suppress his confession. Taylor argued the confession was the product of coercion, that police had failed to follow statutes regarding minors in custody, and that police lacked probable cause for the arrest that led to the confession. The Supreme Court held that the trial court did not err in refusing to exclude Taylor’s statement. The Court noted that witness’ identification of Taylor, his brother and their vehicle provided adequate probable cause for the arrest and that Taylor’s confession had not been the result of coercion. The Court held that although police were alleged to have violated KRS 610.200– which requires that parents of a minor taken into custody must be notified and given a specific account of the charges– the violation did not render the confession inadmissible where it had been otherwise shown to have been given voluntarily.

Taylor testified in his own defense at trial, and upon cross-examination, the prosecutor asked Taylor why he had waited until trial to recant his confession and had not taken advantage of previous opportunities to do so. On appeal, Taylor argued that this questioning violated his right to remain silent. The Supreme Court held that Taylor waived his right to remain silent and noted under Anderson, the prohibition against prosecutorial references to the defendant remaining silent found in Doyle did not apply to cross-examination that merely inquires into prior inconsistent statements. Taylor’s defense at trial was that police deceived him into confessing by making false promises about the consequences of his confession. At trial, Taylor sought to introduce a portion of his brother’s statement to show that the police used deceptive interview practices. The Supreme Court upheld the trial court’s decision that whatever occurred during his brother’s interrogation was irrelevant to Taylor’s claim that he was deceived. Lastly, Taylor wanted to introduce the victim’s outstanding arrest warrants at trial—not as evidence of the victim’s character—rather to bolster his claims that he believed the police when they told him the victim was a wanted criminal and, as such,Taylor's punishment would be light. The Supreme Court said while it was a “close call,” the trial judge’s decision to exclude the victim’s warrants from evidence was not unreasonable or arbitrary and noted that, in any event, the error would have been harmless. 

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