Michael Taylor a/k/a Michael Miguel Taylor a/k/a Michael M. Taylor v. State of Mississippi

CourtCourt of Appeals of Mississippi
DecidedOctober 4, 2022
Docket2021-CP-00917-COA
StatusPublished

This text of Michael Taylor a/k/a Michael Miguel Taylor a/k/a Michael M. Taylor v. State of Mississippi (Michael Taylor a/k/a Michael Miguel Taylor a/k/a Michael M. Taylor v. State of Mississippi) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael Taylor a/k/a Michael Miguel Taylor a/k/a Michael M. Taylor v. State of Mississippi, (Mich. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2021-CP-00917-COA

MICHAEL TAYLOR A/K/A MICHAEL MIGUEL APPELLANT TAYLOR A/K/A MICHAEL M. TAYLOR

v.

STATE OF MISSISSIPPI APPELLEE

DATE OF JUDGMENT: 07/29/2021 TRIAL JUDGE: HON. M. BRADLEY MILLS COURT FROM WHICH APPEALED: MADISON COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: MICHAEL TAYLOR (PRO SE) ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERAL BY: SCOTT STUART NATURE OF THE CASE: CIVIL - POST-CONVICTION RELIEF DISPOSITION: AFFIRMED - 10/04/2022 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE CARLTON, P.J., WESTBROOKS AND SMITH, JJ.

SMITH, J., FOR THE COURT:

¶1. Michael Taylor appeals from the Madison County Circuit Court’s judgment

summarily dismissing his motion for post-conviction collateral relief (PCR) as time-barred.

Finding no error, we affirm.

FACTS

¶2. In March 2014, a Madison County grand jury indicted Taylor for armed carjacking

(Count I) and conspiracy to commit armed carjacking (Count II). Taylor pled guilty to Count

I for armed carjacking, and the State agreed to dismiss Count II for conspiracy to commit

armed carjacking. After finding that Taylor entered his guilty plea to Count I knowingly, intelligently, and voluntarily, the circuit court sentenced Taylor to thirty years in the custody

of the Mississippi Department of Corrections (MDOC), with fifteen years suspended and

fifteen years to serve, followed by fifteen years of post-release supervision. Under

Mississippi’s firearm-enhancement statute, the circuit court sentenced Taylor to an additional

five years in MDOC’s custody, with the term set to run consecutively to the sentence for

Count I. See Miss. Code Ann. § 97-37-37(1) (Supp. 2007) (providing for an additional five-

year term of imprisonment, which “shall not be reduced or suspended[,]” for “any person

who uses or displays a firearm during the commission of any felony . . . .”).

¶3. On July 6, 2021, Taylor filed his PCR motion and argued that the sentence

enhancement imposed under section 97-37-37(1) was illegal and violated his rights to due

process and equal protection under the law. Taylor asserted the circuit court had erred by

enhancing his sentence because the indictment failed to reference the firearm-enhancement

statute and because he received no notice that he would be subject to an enhanced sentence.

The circuit court summarily dismissed Taylor’s PCR motion as time-barred. Aggrieved,

Taylor appeals.

STANDARD OF REVIEW

¶4. We review a circuit court’s “dismissal or denial of a PCR motion for abuse of

discretion” and decline to reverse unless “the [circuit] court’s decision is clearly erroneous.”

Hunt v. State, 312 So. 3d 1233, 1234 (¶6) (Miss. Ct. App. 2021) (quoting Carr v. State, 291

So. 3d 1132, 1137 (¶16) (Miss. Ct. App. 2020)). We review questions of law de novo. Id.

2 “Whether a defendant received fair notice of a sentence enhancement is a question of law

that we review de novo.” Edwards v. State, 305 So. 3d 1186, 1191 (¶14) (Miss. Ct. App.

2020) (quoting Sallie v. State, 155 So. 3d 760, 762 (¶7) (Miss. 2015)), cert. denied, 308 So.

3d 438 (Miss. 2020).

DISCUSSION

¶5. Under the Uniform Post-Conviction Collateral Relief Act, Taylor had three years from

the entry of his judgment of conviction to timely file a PCR motion. Miss. Code Ann. § 99-

39-5(2) (Rev. 2020). Because Taylor filed his PCR motion almost seven years after his 2014

conviction, his PCR motion is clearly time-barred. We recognize, however, that several

“fundamental-rights exceptions have been expressly found to survive procedural bars[,]”

including “the right to be free from an illegal sentence” and “the right to due process at

sentencing . . . .” Creel v. State, 305 So. 3d 417, 421 (¶9) (Miss. Ct. App. 2020) (quoting

Nichols v. State, 265 So. 3d 1239, 1242 (¶10) (Miss. Ct. App. 2018)).

¶6. As the movant, Taylor bears the burden “to show he has met a statutory exception.”

Id. (quoting Williams v. State, 110 So. 3d 840, 843 (¶15) (Miss. Ct. App. 2013)). Our

caselaw holds that “the mere assertion of a constitutional right violation does not trigger the

exception. Rather, there must be some basis of truth for a claim.” Id. (citations and internal

quotation marks omitted).

¶7. Upon review of the record and relevant caselaw, we find that Taylor’s claim lacks

merit. Although Taylor correctly notes that neither the indictment nor his petition to plead

3 guilty referenced section 97-37-37(1), the record reflects that Taylor received proper notice

of the firearm enhancement prior to entering his guilty plea. Although best practice might

be to include formal notice of the firearm-enhancement statute by specific reference within

the indictment, or a subsequent amendment thereto, “[n]o caselaw requires that an indictment

include an actual reference to the sentence enhancement; rather, federal and Mississippi

jurisprudence only require that an indictment include the facts involved in such an applicable

sentence enhancement, such that those facts are required to be proven beyond a reasonable

doubt.” Edwards, 305 So. 3d at 1191 (¶14) (quoting Dortch v. State, 231 So. 3d 1017, 1021

(¶11) (Miss. Ct. App. 2017)). “Here, [Taylor]’s indictment included the facts necessary to

support the sentence enhancement.” Id. at (¶15).

¶8. As this Court previously has explained:

The statutory elements for carjacking under [Mississippi Code Annotated] section 97-3-117 (Rev. 2000) include “(1) a taking of a motor vehicle (2) from someone’s immediate actual possession (3) by force, stealth[,] or violence. Force or violence includes putting the victim in fear of the same. Use of a firearm or other deadly or dangerous weapon elevates the crime to armed carjacking.”

Brown v. State, 282 So. 3d 1192, 1201 (¶35) (Miss. Ct. App. 2019) (quoting Smith v. State,

907 So. 2d 292, 296 (¶17) (Miss. 2005)).

¶9. In the present case, Count I of Taylor’s indictment clearly provided that he and his co-

conspirator used a firearm during the commission of the crime. Specifically, Count I stated

that Taylor and his co-conspirator committed armed carjacking by

willfully, unlawfully, feloniously[,] and knowingly tak[ing] from the

4 immediate actual possession of [the victim] a 2007 Toyota Camry [a]utomobile, the personal property of [the victim], by putting the said [victim] in fear, by the exhibition of a deadly weapon, to-wit: a hand[]gun . . . in violation of [section] 97-3-117 . . . .

¶10. Taylor’s plea petition indicated that he previously had been convicted of a felony.

During the plea hearing, Taylor confirmed his prior felony conviction when questioned by

the circuit judge. Also during the plea hearing, the State provided the factual basis for its

case against Taylor. The State’s recitation included the fact that Taylor and his co-

conspirator had used a gun to commit the carjacking. After Taylor indicated that he had no

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Related

Smith v. State
907 So. 2d 292 (Mississippi Supreme Court, 2005)
Craig D. Sallie v. State of Mississippi
155 So. 3d 760 (Mississippi Supreme Court, 2015)
David Nichols v. State of Mississippi
265 So. 3d 1239 (Court of Appeals of Mississippi, 2018)
Williams v. State
110 So. 3d 840 (Court of Appeals of Mississippi, 2013)

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Bluebook (online)
Michael Taylor a/k/a Michael Miguel Taylor a/k/a Michael M. Taylor v. State of Mississippi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-taylor-aka-michael-miguel-taylor-aka-michael-m-taylor-v-state-missctapp-2022.