Taylor v. Dayton

Background

Kemen Lavatos Taylor, II was indicted on two murder counts and convicted on both counts on March 5, 2014. During his trial, the Minnesota trial court required courtroom spectators to show photographic identification before entering the courtroom. Taylor argued that this requirement prevented several family members and friends from attending and violated the Sixth Amendment right to a public trial.

Taylor raised that argument on direct appeal to the Minnesota Supreme Court, which affirmed his conviction on August 26, 2015. The state court held that the identification requirement was too minor to constitute a true closure of the trial. Taylor later sought post-conviction relief so he could present evidence that community members and relatives had been denied access. The state courts denied that request under Minnesota’s rule barring relitigation of matters already fully and fairly litigated and matters that could have been raised on direct appeal.

Taylor then filed an amended petition under 28 U.S.C. § 2254, the federal law allowing a person in state custody to challenge a state-court conviction. A magistrate judge recommended dismissing the petition and denying a certificate of appealability, which is permission to appeal a habeas ruling. Taylor objected.

Court’s analysis

The court reviewed the magistrate judge’s recommendation independently and adopted it. Regarding the public-trial claim, the court held that Taylor had not shown that the Minnesota Supreme Court’s decision was contrary to, or an unreasonable application of, clearly established United States Supreme Court law. The court explained that Waller v. Georgia and Presley v. Georgia address whether a courtroom closure was justified after an actual closure occurred; they do not establish the standard for deciding whether the identification requirement created a constitutionally significant closure in the first place.

The court also agreed that Taylor procedurally defaulted his effort to supplement the record. Procedural default is a rule that generally prevents federal review when a state court declined to decide a federal claim because the petitioner failed to follow a state procedural requirement. The court found that Taylor should have requested record supplementation during his direct appeal and had not shown a basis to excuse that default.

The court rejected Taylor’s argument that the Minnesota Supreme Court misapplied Crane v. Kentucky regarding alternative-motive evidence. It agreed that Crane did not address that type of evidence and therefore was not applicable. The court also held that cumulative error—the argument that several alleged mistakes together require relief—could not support Taylor’s petition because, under the cited Eighth Circuit precedent, each claim had to succeed or fail independently.

Ruling

Judge David S. Doty overruled Taylor’s objection and adopted the report and recommendation. The court dismissed the amended § 2254 petition with prejudice, meaning this petition could not be filed again in the same form. The court granted a certificate of appealability solely on the alleged violation of Taylor’s public-trial right, finding that the issue was sufficiently debatable to warrant further proceedings. The certificate did not extend to Taylor’s other claims.