Taylor v. Delaware

Milton Taylor appeared before a superior court judge and offered to plead guilty but mentally ill for the July 2016 murder of Whitney White. After his counsel told the court that Taylor was competent to plead guilty, the court conducted a plea colloquy with him but deferred accepting the plea until a later sentencing hearing, when the court would have the presentence investigation. The day after the hearing, Taylor told his counsel to withdraw his plea. His counsel refused. Taylor then made pro se requests to withdraw his plea. The court would not consider them because Taylor had counsel. At the sentencing hearing, Taylor addressed the court and sought again to withdraw his plea. The trial judge refused to consider Taylor’s request because Taylor had counsel. Over Taylor’s objection, the court accepted the guilty but mentally ill plea to manslaughter and possession of a deadly weapon during commission of a felony, and sentenced Taylor to 45 years in prison. Taylor appealed. After review, the Delaware Supreme Court determined: (1) Taylor waived his right to object to the “sole issue” statutory requirement - the State and counsel agreed the plea hearing could be conducted in two parts; (2) Taylor did not cooperate with the presentence investigation; (3) defense counsel’s refusal to withdraw Taylor’s plea violated Taylor’s Sixth Amendment autonomy interest to decide the objective of his defense (having represented to the court that Taylor was competent to plead guilty, defense counsel should have followed Taylor’s demand to withdraw his plea before the court accepted it); (4) under Superior Court Criminal Rule 11, before adjudicating a defendant guilty but mentally ill by plea, the court must address the defendant in open court and be satisfied that the defendant is entering his plea knowingly, intelligently, and voluntarily - before the court accepted Taylor’s plea, he objected, thus, Taylor could not have entered his plea voluntarily. The Supreme Court therefore vacated Taylor’s conviction, and remanded this case back to the superior court for his counsel to review with Taylor whether he should withdraw his plea. If he was competent to make the decision and insisted on withdrawing his guilty but mentally ill plea, the court should allow Taylor to withdraw his plea and proceed to trial. View "Taylor v. Delaware" on Justia Law