Taylor, Richard Owen

CourtCourt of Appeals of Texas
DecidedAugust 18, 2015
DocketWR-41,683-04
StatusPublished

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Bluebook
Taylor, Richard Owen, (Tex. Ct. App. 2015).

Opinion

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New Boston¢ Tx August 14, 2015 Texas Court of Criminal Appeals, Clerk of Court P.O. Box 12308 . Austin/ Tx 78711-2308

Re: No.,WR-4l,683-02, Ex parte Richard Owen Taylor

Dear Clerk:

Enclosed,please kindly find my Objections to be filed with the papers in this case. The trial court clerk has Submitted the record to this court. “

With kindest regards, I am

Very truly yours

chard Owen”Taylor Pro se Applicant

Encl. `cc: 'Andrea Jacobs

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NO. WR-4l,683-02

IN THE

COURT-OF CRIMINAL APPEALS OF TEXAS

Ex parte

Richard Owen Taylor

On Successive Application for a Writ of Habeas Corpus Seeking relief from Final Conviction Under Code of Criminal Procedure, Article ll.O7; in the Criminal

District Court Number Four of Tarrant County, Texas, in Cause Number C-4-010509-0577954-B

Taylor's Objections to the Trial Court's Adoption of State's Proposed Memorandum, Findings of Fact and Conclusions of Law

Richard Owen Taylor TDCJ# 816002

Telford Unit

3899 State Hwy 98 New Boston/ Tx 75570

Pro se Applicant

Date: August 141 2015

To the Honorable Court of Criminal Appeals:

Taylor urges this Court to reject the trial court's findings

of fact,

conclusions of law, and recommendations to dismiss this

case and to remand this case for full consideration on the merits.

The claims have not yet been considered. In deciding whether the

merits of Taylor's successive application should be considered, this

Court is presented with four straightforward issues:

*

,The Supreme Court recently held that the 6th Amendment

guarantees the right to effective assistance of counsel during a plea consideration and negotiation. In Taylor's initial application, he alleged that his 40 year plea bargain was involuntarily made, but did not complain about counsel's ineffectiveness during the prior 25 year plea offer because no constitutional rights had attached. Could Taylor have formulated this argument in his initial

' application and, if not, was counsel' s ineffectiveness

during the prior plea negotiation and consideration previously resolved?

The Supreme Court recently held that persons who commit crimes while they are under 18 years of age are not as morally culpable as similarly disposed adult offenders/

and noted the difficulties for even experts to differentiate between immaturity/ and the rare juvenile offender whose` crimes reflect irreperable corruption. This Court has

'retroactively applied this new rule. Was the factual or

legal basis for the claim of newly recognized mitigating factors unavailable to Taylor when he filed the initial application?

In Ex parte Tiede, this Court found that a revelation of suppressed childhood trauma was newly available relevant scientific evidence. In this case/ Taylor had a recent revelation of suppressed sexual abuse by his older brother, who not only orchestrated the aggravated robbery, but who influenced Taylor into participating. This revelation occurred some 16 years after his initial application was

'filed.. Does Taylor's successive application contain ' sufficient specific facts establishing that the legal or -factual basis for his claim was unavailable at the time

he filed his initial application?

Page l

* The Supreme Court has recently held that the 8th Amendment mandates States to provide juveniles with a meanginful opportunity to return to society once they have demonstrated maturity and rehabilitation. Does this new rule create a liberty interest in parole for juvenile offenders?

Argument and Authorities

The Court should consider the merits of this application.

'Article 11.07 § 4 sets out the procedure for filing a successive

application for writ of habeas corpus. The Article provides that:

Tex.

(a)If a subsequent application for writ of habeas corpus is filed after final disposition of an initial application challenging the same conviction, a court may not consider

the merits of or grant relief based on subsequent application unless the application contains sufficient specific facts establishing that:- F

(1)the current claims and issues have not been and could not have been presented previously in an original application or in a previously considered application filed under this article because the factual or legal bisis for the claim was unavailable on the date the applicant filed the previous application; or

(2)by a preponderance of the evidence, but for a violation of the United States Constitution no rational juror could have found the applicant guilty beyond a reasonable doubt.

(b)For purposes of Subsection (a)(l), a legal basis of a claim is unavailable on or before a date described by Subsection: (a)(l) if the legal basis was not recognized by and could not have been reasonably formulated from a final decision of the United States Supreme Court, or a court of appeals of the United States, or a court of appellate jurisdiction of this state on or before that date.

(c)For purposes of Subsection (a)(l), a factual basis of‘a claim is unavailable on or before a date described by Sub- section (a)(l) if the factual basis was not ascertainable through the exercise of reasonable diligence on or before that date.

Code Crim. Proc. Ann. art. 11.07, § 4.

Taylor has stated sufficient specific facts establishing that

Page 2

his first and second grounds for relief could not have been raised in his initial application» l. The courts did not recognise plea bargaining procedings as

a critical stage requiring effective assistance of counsel

until the U.S. Supreme Court decisions in Lafler and §£y§.

The Sixth Amendment's guarantee of "assistance of counsel" for the defense of an accused has long been held to mean that a criminal defendant has a right to the effective assistance of counsel. The Supreme Court has interpreted this right as extending to all "critical stages" of a criminal proceeding. In Missouri v. Frye, the Court examined the issue of whether the Sixth Amendment's guarantee of effective assistance of counsel encompasses the negotiation and consideration of plea offers.l

In §£ye, the defendant was accused of driving with a revoked license - an offense for which Frye had been convicted three times before. The prosecution extended two alternative plea recommendations. First, the prosecution proposed a three-year sentence with a guilty plea to a felony charge including no probation recommendation and a suggestion that Frye serve ten days "shock time" in jail. Alter- natively, the prosecution suggested the reduction of Frye's charges to a misdemeanor and a ninety-day jail sentence if Frye agreed to plead guilty. Each recommendation was formal and included an

expiration date. Defense counsel allowed both offers to lapse without

communicating either of the prosecution's proposed plea recommendations

` l. 132 S.Ct. 1399 (2012).

Page 3

to Frye. Subsequently, he was sentenced to three years in jail. After learning of the lapsed plea offers, Frye applied for relief after the court entered his conviction, alleging ineffective assistance of counsel. He argued that had he known of the offered plea recommendations, he would have pleaded guilty to the misdemeanor.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Roper v. Simmons
543 U.S. 551 (Supreme Court, 2005)
Lafler v. Cooper
132 S. Ct. 1376 (Supreme Court, 2012)
Missouri v. Frye
132 S. Ct. 1399 (Supreme Court, 2012)
Holder v. Martinez Gutierrez
132 S. Ct. 2011 (Supreme Court, 2012)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)

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