Taylor: No habeas relief because no Due Process violation in exclusion of defense evidence

In Taylor v. Sec., Fla. Dep’t of Corrections, No 12-12112 (July 28, 2014), the Court affirmed the denial of habeas relief to a Florida inmate sentenced to death for a 1988 murder. The Court rejected the argument that Taylor’s due process rights were violated when the trial court did not allow him to present evidence that the murder victim occasionally used or purchased crack cocaine, which would have corroborated Taylor’s defense that the victim consented to sex on the night of her murder. The Court noted that the testimony had no direct bearing on the issue of sexual consent, and would not have materially supported Taylor’s defense. The Court also rejected the argument that defense counsel was ineffective for having Taylor reenact the crime on the witness stand. The Court noted that Taylor did not in fact physically reenact the crime, and counsel’s tactical choices were not constitutionally deficient.