Taylor v. State, 84 N.Y.2d 856 (1994)
A claimant seeking damages for unjust conviction and imprisonment must prove by clear and convincing evidence that they did not cause or bring about their own conviction through their own conduct.
Summary
Bruce Taylor sought damages from the State of New York for unjust conviction and imprisonment after his drug conviction was vacated due to prosecutorial misconduct. The Court of Claims denied his claim, finding he failed to prove he did not cause his conviction. The Appellate Division affirmed, and the Court of Appeals affirmed as well, holding that Taylor’s untruthful testimony and direction to his attorney not to call his wife as a witness (to protect her, not to help his case) demonstrated he contributed to his conviction, barring recovery under Court of Claims Act § 8-b.
Facts
Bruce Taylor was convicted in 1974 for selling a controlled substance. He served over five years in jail and four years on probation. The conviction was vacated under CPL 440.10 due to prosecutorial misconduct, specifically false testimony by the arresting officer and failure to disclose information about the informant. Taylor then sued the State under Court of Claims Act § 8-b for unjust conviction and imprisonment.
Procedural History
The Court of Claims denied Taylor’s claim. The Appellate Division affirmed the Court of Claims decision. Taylor appealed to the New York Court of Appeals.
Issue(s)
Whether Taylor proved by clear and convincing evidence that he did not cause or bring about his own conviction, as required by Court of Claims Act § 8-b(5)(d), despite his conviction being vacated due to prosecutorial misconduct.
Holding
No, because Taylor’s less-than-candid testimony at trial regarding his involvement in the drug transaction and his decision to prevent his wife from testifying to protect her, contributed to his conviction.
Court’s Reasoning
The Court of Appeals affirmed the lower courts’ findings that Taylor failed to prove he did not contribute to his conviction. The court noted that Taylor’s trial testimony was not entirely truthful regarding his role in the drug sale. More importantly, the court highlighted that Taylor instructed his attorney not to call his wife as a witness, not to help his own defense, but rather to shield her from potential legal repercussions related to the crime. This action, the court reasoned, constituted conduct that contributed to his conviction, thus precluding him from recovering damages under the unjust conviction statute. The court distinguished this case from situations involving mere trial strategy, stating that the decision to prevent his wife’s testimony was made to protect her, not to advance his own cause. As the court stated, “There is evidence in the record that supports the findings below that Taylor directed his attorney not to call his wife to testify in order to protect her, rather than to advance his own cause. Thus, the court’s consideration of that decision was not impermissible consideration of trial strategy.”