United States Ex Rel. Taylor v. Gilmore

Citations: 770 F. Supp. 445; 1990 U.S. Dist. LEXIS 19438; 1990 WL 303941Docket: 90-1211

Court: District Court, C.D. Illinois; December 19, 1990; Federal District Court

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Petitioner Kevin Taylor sought habeas corpus relief under 28 U.S.C. § 2254, claiming that the jury instructions from his trial violated his constitutional right to due process. The United States District Court for the Central District of Illinois denied his petition. Taylor had been convicted of murder and home invasion, receiving concurrent sentences of 35 years and six years, respectively, after a jury trial in Sangamon County. The incident occurred on September 14, 1986, when Taylor, following a confrontation with his ex-wife’s boyfriend, Scott Siniscalchi, broke into their home and fatally stabbed Scott during a struggle. At trial, Taylor argued he acted in a sudden and intense passion, warranting a conviction only for voluntary manslaughter. The jury received detailed instructions regarding the elements of both murder and voluntary manslaughter, ultimately convicting Taylor of murder. His conviction was affirmed by the Illinois Appellate Court, and subsequent appeals to the Illinois Supreme Court and post-conviction relief efforts were unsuccessful.

Approximately one year after Taylor's direct appeals were exhausted, the Illinois Supreme Court issued its ruling in People v. Reddick, determining that the jury instructions used in Taylor's trial were a 'grave error.' The Reddick court concluded that these instructions allowed a jury to convict a defendant of murder even if mitigating factors supporting a voluntary manslaughter finding were present. Following Reddick, Taylor petitioned for habeas relief, claiming that the jury instructions violated his due process rights. The state conceded that the jury instructions constituted a due process violation under current law, aligning with the Seventh Circuit's interpretation in Falconer v. Lane, which held that the Reddick decision was based on constitutional due process considerations.

Despite acknowledging the constitutional defect, the state contended that Taylor should not receive habeas relief for two primary reasons: First, under Teague v. Lane, the Reddick decision should not apply retroactively to Taylor's conviction since it established a new constitutional rule after his conviction became final. Taylor's conviction was finalized on May 9, 1987, when the Illinois Supreme Court denied leave to appeal, or 90 days later when the period for seeking certiorari expired. Conversely, Reddick was decided on June 20, 1988. Second, the state argued that any error from the jury instructions was harmless. Teague's general rule specifies that new constitutional rules of criminal procedure do not apply retroactively to cases that were finalized before such rules were announced. The state maintained that Reddick announced a new rule not in effect at the time of Taylor's conviction, and thus, for Reddick to apply retroactively, it must not have established a 'new constitutional rule of criminal procedure.' The definition of a 'new rule' from Teague indicates that it occurs when a case breaks new ground or imposes new obligations not previously dictated by existing precedent.

The key issue is whether the Reddick decision established a new constitutional principle. Taylor argues that Reddick should have retroactive application because it was based on established constitutional principles, citing People v. Flowers, where the Illinois Appellate Court supported this view by stating that Reddick was grounded in well-settled law. However, the Appellate Court did not provide case law to substantiate the claim that Reddick was clearly based on existing law. The state contends that Reddick introduced a new legal principle, supported by the Illinois Supreme Court's reversal in Flowers, which confirmed that Reddick indeed announced a new constitutional rule of criminal procedure. 

Although Reddick aligned with existing affirmative defense laws, it was the first application of these principles to murder and voluntary manslaughter instructions, determining them erroneous and implicating constitutional rights. This conclusion did not arise from previous statutory analysis or existing precedent, as trial courts had traditionally instructed juries according to Illinois Pattern Jury Instructions without prior invalidation. 

The court agrees with the Illinois Supreme Court's rationale that Reddick invalidated entrenched jury instructions and parallels the Seventh Circuit's view in Falconer, which also suggested a new constitutional rule concerning jury instructions. Since Reddick constituted a new rule, it can only be applied retroactively to Taylor's case if it fits within the two exceptions to the Teague rule against retroactive applications. However, neither exception applies: the Reddick rule does not place specific conduct beyond state law, as murder prosecution remains valid under Reddick.

The rule established in Reddick is not considered a procedure inherent to the concept of ordered liberty, a term originating from Justice Cardozo's opinion in Palko v. Connecticut, which restricts this concept to fundamental constitutional rights. Cardozo's examples, such as trial by jury and immunity from self-incrimination, indicate that only the most essential doctrines qualify. Consequently, the standards from Reddick and Falconer cannot be retroactively applied to Taylor's conviction. The court finds it unnecessary to evaluate the state's argument regarding harmless error since the trial court's jury instructions do not constitute error without retroactive application of Reddick and Falconer. Although it is acknowledged that the jury instructions violated due process, this was not recognized at the time of Taylor's conviction. As a result, earlier rulings declaring these instructions unconstitutional do not support Taylor's request for habeas relief. Taylor's Petition for Habeas Corpus Relief is therefore denied.