Samuel Lamar Taylor a/k/a Samuel Taylor v. State of Mississippi

Summary

The Mississippi Court of Appeals affirmed Samuel Lamar Taylor’s convictions for sexual battery and gratification of lust against a minor, as well as consecutive sentences of life imprisonment and fifteen years. The court held that Taylor’s indictment provided sufficient notice despite its two-year date range and statutory language, and that challenges to the admission of the minor’s disclosures were procedurally barred or harmless.

Holdings

1. The indictment was not defective. In child-sexual-abuse cases, a general timeframe may be sufficient when the indictment otherwise fully and fairly advises the defendant of the charges, and Taylor did not show that the date range prejudiced his defense.
2. Count II was sufficient. The indictment's tracking of the statutory language adequately informed Taylor of the charged offense because the specific method of gratifying lust was not an essential element.
3. The claim was procedurally barred because Taylor did not contemporaneously object to the testimony, report, or note. Even absent the bar, any error was harmless because the remaining evidence overwhelmingly supported the convictions.
4. The bolstering claim was waived because Taylor did not object to the testimony of the mental-health specialist or forensic interviewer, or to admission of the related report and CAC interview.

Questions Presented

1. Whether the indictment was legally insufficient because the charged offenses were alleged to have occurred within a two-year date range.
2. Whether the gratification-of-lust count was insufficient because it tracked the statutory language and did not specify the particular conduct or method of touching.
3. Whether the admission of the child's disclosures through a mental-health specialist's testimony and report required reversal because the trial court did not make an on-the-record tender-years reliability finding.
4. Whether the State improperly bolstered the child's trial testimony through testimony from the mental-health specialist and forensic interviewer.

Disposition

affirmed