Taylor v. Wall

Summary

The Supreme Court of Rhode Island affirmed the denial of Sydney Earl Scott Taylor's application for post-conviction relief. The court held that Taylor's challenge to an allegedly prejudicial jury comment was barred by waiver and res judicata principles, and that the videotaped testimony procedure for the child victim satisfied the Confrontation Clause requirements. The court also concluded that Maryland v. Craig did not apply retroactively to provide relief.

Holdings

1. The challenge was barred because it could have been raised on Taylor's direct appeal and therefore was precluded by Rhode Island's post-conviction-relief waiver provision, which codifies res judicata principles.
2. The procedure did not violate Taylor's Sixth Amendment confrontation right because the trial justice made the required case-specific finding that the child would suffer unreasonable and unnecessary mental and emotional harm from testifying in Taylor's presence, and the testimony was subject to oath, cross-examination, and observation by the judge and jury.
3. The delayed broadcast of the child's prerecorded testimony did not deprive Taylor of his Sixth Amendment right of confrontation.
4. Even if Craig announced a new rule, it would not apply retroactively to Taylor's collateral proceeding because it did not fall within either recognized exception for retroactive application of new criminal-procedure rules.

Questions Presented

1. Whether Taylor's challenge to an allegedly prejudicial trial-justice comment was barred by Rhode Island's post-conviction-relief waiver and res judicata provision.
2. Whether permitting the child victim to testify by prerecorded videotape outside Taylor's physical presence violated the Sixth Amendment right of confrontation under Maryland v. Craig.
3. Whether the delayed presentation of the prerecorded testimony deprived Taylor of the opportunity for contemporaneous cross-examination and therefore violated the Sixth Amendment.
4. Whether Maryland v. Craig announced a new rule that could be applied retroactively on collateral review.

Disposition

affirmed