QUANTEL TAYLOR v. STATE OF TENNESSEE - Articles

All Content

QUANTEL TAYLOR v. STATE OF TENNESSEE

Posted by: Tanja Trezise on Aug 21, 2014

Court: TN Supreme Court

Attorneys 1:

Marty B. McAfee and Gregory D. Allen (on appeal), Memphis, Tennessee; and S. Jasper Taylor IV (at trial and on appeal), Bells, Tennessee, for the appellant, Quantel Taylor.

Attorneys 2:

Robert E. Cooper, Jr., Attorney General and Reporter; William E. Young, Solicitor General; Jeffrey D. Zentner, Assistant Attorney General; Garry G. Brown, District Attorney General; and Hillary Lawler Parham, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge(s): WADE

The petitioner pled guilty to charges of attempted first degree murder, second degree murder, and especially aggravated robbery. Later, he filed a petition for post-conviction relief, claiming that his trial counsel was ineffective and that his guilty pleas were not knowingly and voluntarily made. When the petitioner subpoenaed his three co-defendants to testify at the post-conviction hearing, the State filed a motion to quash because the co-defendants were all incarcerated. The post-conviction court granted the State’s motion. The Court of Criminal Appeals ruled that the post-conviction court had erred, but held that the error was harmless under the circumstances. We hold that the post-conviction court committed prejudicial error by applying an incorrect legal standard and by failing to consider whether the proposed testimony by the co-defendants was material to the petitioner’s claim of ineffective assistance of counsel. Because the record is insufficient for the issue to be resolved on appeal, we remand for the post-conviction court to reconsider the motion to quash under the proper standard. The judgment of the Court of Criminal Appeals is reversed, and the case is remanded to the post-conviction court for additional proceedings consistent with this opinion.

Attachments: