Taylor v. State

• Court: Supreme Court of Georgia
• Decided: October 15, 2025
• Docket: S25A0727
• Status: Published

Opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

In the Supreme Court of Georgia

Decided: October 15, 2025

S25A0727. TAYLOR v. THE STATE.

LAND, Justice.

A jury found Micah Blake Taylor guilty of malice murder and

related crimes in connection with the killing of Regina Trotter.1 On

appeal, Taylor argues that the trial court erroneously admitted

social media and cell phone records because the search warrants

that led to the seizure of those records lacked probable cause. For

1 The crimes occurred on January 31, 2021. In August 2021, a Heard

County grand jury indicted Taylor and co-defendant Jenae Dickinson for malice murder, felony murder, two counts of aggravated assault, and concealing the death of another. Dickinson pleaded guilty to one count of aggravated assault and concealing the death of another and testified against Taylor at trial. In March 2023, Taylor was tried before a jury and was found guilty of all counts. The trial court sentenced Taylor to serve life in prison without the possibility of parole for malice murder and a consecutive ten-year term in prison for concealing the death of another; the remaining counts merged or were vacated by operation of law. Taylor filed a timely motion for new trial, which he amended through new counsel. Following a hearing, the trial court denied Taylor’s motion, as amended, on September 11, 2024. Taylor filed a timely notice of appeal, and the case was docketed to this Court’s April 2025 term and submitted for a decision on the briefs. 1 the reasons that follow, Taylor’s claims fail, so we affirm.

1. The evidence at Taylor’s trial showed as follows. Before her

murder, Trotter lived in Heflin, Alabama with Taylor and her friend

Jonathan Bryant. The aunt of Trotter’s boyfriend had loaned Trotter

a van, and on January 31, 2021, Taylor took Trotter’s van without

permission to visit his friend and Jenae Dickinson at her residence

near the Georgia-Alabama state line. Taylor and Dickinson returned

to Trotter’s home with the van later that day, and Trotter told Taylor

he could no longer stay at her home because he took the van without

permission. Trotter then agreed to drive Taylor and Dickinson back

to Dickinson’s home. On the ride, Trotter drove, Dickinson sat

“propped up behind the passenger seat,” and Taylor sat in the back

bench seat.

Nearing Dickinson’s home, Dickinson directed Trotter down a

dirt road and instructed her to pull up to a gate. As Trotter slowed

the van, Taylor put “something” around Trotter’s neck and began to

strangle her. Dickinson put the van in park, and Taylor pulled

Trotter into the rear of the van and told Dickinson to drive.

2 Dickinson heard Taylor and Trotter “scuffling” and Trotter

struggling to breathe. Dickinson stopped the van at Taylor’s

direction, and she then heard Taylor drag Trotter out of the vehicle.

Taylor returned to the van alone, and he and Dickinson drove away.

The next day, hunters found Trotter’s body in a roadside ditch

in rural Heard County. She had a braided rope tied around her

throat and lacerations to her face and neck. An autopsy determined

the causes of death to be strangulation and sharp-force injuries to

the head and neck. Investigators located a set of brass knuckles near

Trotter’s body, as well as Great Value-brand canned potatoes.

Shortly after the crimes, investigators executed a search

warrant at Dickinson’s residence and found rope like the one found

tied around Trotter’s neck. Multiple witnesses later testified to

seeing Taylor in possession of Trotter’s van and purse hours after

she was murdered, and investigators soon located Trotter’s van,

since reported stolen by Trotter’s boyfriend’s aunt, with Taylor

asleep inside. Also inside the van, investigators found the same

Great Value-brand canned potatoes as those found by Trotter’s body.

3 Finally, investigators found a bloody towel that testing later

revealed to contain DNA matching Taylor, Trotter, and Dickinson.

Subsequent testing also identified Taylor’s DNA on the brass

knuckles found at the crime scene, and Dickinson later testified that

those brass knuckles resembled the brass knuckles Taylor had

shown her on the day of Trotter’s murder.

Following Taylor’s arrest, investigators sought and obtained

multiple search warrants, one seeking ten days of Taylor’s cell phone

records, including call logs and cell site location data, and another

seeking four days of Taylor’s Facebook account activity. Among

other things, the warrants yielded various text messages between

Taylor and Trotter, including messages where they argued about the

van on the day of Trotter’s murder, and a Facebook message from

Taylor to Dickinson, sent two weeks before Trotter’s murder, asking

whether Dickinson knew of a “chop shop.”2

While incarcerated before trial, Taylor described Trotter’s

2 A “chop shop” is a “a place where stolen automobiles are stripped of

salable parts.” Merriam-Webster Dictionary, https://www.merriam- webster.com/dictionary/chop%20shop (website last accessed Oct. 1, 2025).. 4 murder to his cellmate, who testified at trial that Taylor acted out

Trotter’s stabbing. Jail surveillance footage played at trial showed

Taylor speaking with the cellmate and his reenactment of stabbing

Trotter.

2. On appeal, Taylor argues that the trial court erred in

admitting evidence of his Facebook message asking Dickinson

whether she knew of a chop shop because the search warrant used

to obtain that message failed to meet the Fourth Amendment’s

probable cause requirement. See Tatum v. State, 319 Ga. 187, 191

(2024) (“[T]he United States Supreme Court created the

exclusionary rule, a deterrent sanction that bars the prosecution

from introducing evidence obtained by way of a Fourth Amendment

violation.” (citation and punctuation omitted)); Pugh v. State, 318

Ga. 706, 713 (2024) (the Fourth Amendment to the United States

Constitution requires that search warrants be predicated on

probable cause “to believe both that a crime is being committed or

has been committed and that contraband or evidence of a crime will

be found in a particular place.” (citation and punctuation omitted)).

5 Taylor also asserts that admission of the Facebook messages

harmed him by strengthening the State’s theory that he killed

Trotter to steal her van.

Our review of the record reflects that, while Taylor objected to

the admission of the Facebook records on relevance grounds at trial,

he raised the probable-cause challenge to the search warrant used

to obtain those records for the first time in his motion for new trial.

So we review this claim for plain error only. See Williams v. State,

315 Ga. 490, 494–95 (2023) (applying plain-error review to

particularity challenge to search warrant where appellant did not

challenge the warrant on that basis before trial or when the evidence

obtained with that warrant was introduced at trial). To establish

plain error, Taylor “must demonstrate that the alleged error was not

affirmatively waived; was clear or obvious, rather than subject to

reasonable dispute; affected his substantial rights, meaning that it

affected the outcome of the trial court proceedings; and seriously

affect[ed] the fairness, integrity, or public reputation of judicial

proceedings.” Pugh, 318 Ga. at 717 (cleaned up). “Satisfying all four

6 prongs of this standard is difficult, as it should be,” id., and this

Court does “not have to analyze all elements of the plain-error test

where an appellant fails to establish one of them.” Durden v. State,

318 Ga. 729, 733 (2024) (citation and punctuation omitted).

Even assuming the search warrant failed to establish probable

cause, Taylor’s claim fails under the third prong of the plain-error

test because he cannot show that the alleged error affected his

substantial rights. Pugh, 318 Ga. at 719.First, the Facebook

evidence was largely cumulative. Although Taylor argues that the

State used evidence of the “chop shop” message to support its theory

that he murdered Trotter to steal her van, the State also introduced

evidence that Taylor did, in fact, steal Trotter’s van after he killed

her, including eyewitness testimony that Taylor was seen with

Trotter’s van in the hours after she was murdered and investigators’

discovery of Taylor asleep inside the van. And the State elicited

Dickinson’s testimony that Taylor told her—shortly before Trotter’s

murder—that he hoped the van would soon be his. Thus, the “chop

shop” message was cumulative. See, e.g., Johnson v. State, 319 Ga.

7 562, 571–72 (2024) (where challenged evidence was merely

cumulative of other properly admitted evidence, any error in its

admission did not affect defendant’s substantial rights).

Second, the evidence of Taylor’s guilt was overwhelming. In

addition to Dickinson’s eyewitness testimony and Taylor’s

admissions to his cellmate detailing Trotter’s murder, witness

testimony established that Taylor was with Trotter immediately

before her murder and that he was in possession of Trotter’s van and

purse shortly after her murder. Police arrested Taylor upon finding

him asleep inside Trotter’s van. And investigators later connected

Taylor to physical evidence found at the location where Trotter’s

body was dumped. Taylor offers no reason that the verdict would

have been any different had evidence obtained with the challenged

warrant been excluded. He has therefore failed to meet his burden

of showing that any error in the admission of the evidence obtained

from his Facebook account likely affected the outcome of his trial,

and this enumeration fails. See Ruthenberg v. State, 317 Ga. 227,

231 (2023) (where the State presented overwhelming evidence of

8 appellant’s guilt, including evidence of appellant’s own admissions

of guilt and eyewitness testimony identifying him as the killer,

appellant failed to satisfy third prong of plain-error test).

3. Taylor next argues that the trial court erred in denying his

motion to suppress cell phone records obtained from his service

provider because the warrant used to obtain those records lacked

probable cause. Assuming without deciding that the warrant lacked

probable cause, we conclude that any error in the denial of Taylor’s

motion to suppress was harmless beyond a reasonable doubt and

does not require reversal. See Hill v. State, 310 Ga. 180, 188–89

(2020) (even “[w]hen the admission of evidence is an error of

constitutional magnitude, it can be harmless error if the State can

prove beyond a reasonable doubt that the error did not contribute to

the verdict, such as when the evidence at issue is cumulative of other

properly-admitted evidence or when the evidence against the

defendant is overwhelming.” (citation and punctuation omitted)).

Here, the record shows that evidence obtained with the

challenged warrant and introduced at trial included Taylor’s

9 incoming and outgoing text messages and calls around the time of

the murder. The State mainly used this evidence to detail Taylor’s

communications with Dickinson and Trotter on the day of Trotter’s

murder. And those communications revealed Trotter’s frustration

with Taylor for taking her van, her repeated requests that he return

it, and Taylor’s noncommittal responses.

These records, however, were almost entirely cumulative of

other properly introduced evidence. The State also admitted

evidence of Trotter’s calls and messages and specifically elicited

testimony that those records were identical to Taylor’s as to

communications between the two. Indeed, the State relied primarily

on Trotter’s phone records for evidence of communications between

her and Taylor. Likewise, multiple witnesses testified about Taylor’s

and Trotter’s communications with each other and with third

parties on the days surrounding the murder, much of which

concerned Taylor and Trotter’s dispute over the van.

Moreover, as we have already discussed, the other evidence of

Taylor’s guilt was substantial. The State presented significant

10 incriminating evidence, including Dickinson’s testimony about how

Taylor murdered Trotter, Taylor’s confession to his cellmate,

Taylor’s reenactment of the murder on surveillance video, and

Taylor’s DNA at the crime scene. Under these circumstances, any

error in the trial court’s admission of the evidence obtained with the

challenged warrant was harmless beyond a reasonable doubt, so this

enumeration also fails. See Hill, 310 Ga. at 188–89 (rejecting Fourth

Amendment challenge to warrant because disputed evidence was

cumulative and rendered assumed error harmless); Hinkson v.

State, 310 Ga. 388, 402–03 (2020) (any error in trial court’s denial of

motion to suppress on Fourth Amendment grounds was harmless

given overwhelming evidence of appellant’s guilt).3

3 Taylor also claims the trial court erroneously denied his motion for a

new trial. But Taylor supports this enumeration only by repeating his claim that the trial court should have excluded evidence obtained via the challenged warrants and by citing State v. Lane, 308 Ga. 10 (2020), apparently suggesting that these errors cumulatively prejudiced him. To the extent Taylor has asserted a cumulative error claim, he offers no argument or citation to the record or the law to explain how the purported evidentiary errors harmed him, and we discern no prejudice on this record. See id. at 18 (“[A] defendant who wishes to take advantage of the [cumulative error] rule … should explain to the reviewing court just how he was prejudiced by the cumulative effect of multiple errors.”). 11 Judgment affirmed. All the Justices concur.