Taylor v. Maddox

Around 11:30 p.m., police officers and detectives arrested 16-year-old Leif Taylor (plaintiff) as a suspect in a shooting death. Detectives questioned Taylor for over two hours. It was disputed whether the detectives advised Taylor of his Miranda rights prior to the questioning. During the interrogation, Taylor repeatedly denied any involvement in the shooting and frequently asked for his mother and a lawyer. The detectives denied Taylor access to both. There was no audio or video recording of the questioning. Around 2:30 a.m., Taylor waived his Miranda rights and made an 11-minute confession on audio tape. After Taylor made the confession, the detectives permitted him to make a phone call to his attorney. During the phone call, he detailed what transpired during the interrogation. The State of California charged Taylor with first-degree felony murder and second-degree robbery. At trial, Taylor filed a motion to suppress the audio confession, arguing that the detectives obtained it illegally. At the suppression hearing, Taylor argued that he repeatedly asked for a lawyer during the questioning. Taylor testified that the detectives threatened him with a long prison sentence if he did not confess. Explaining why he gave the confession, Taylor said he was tired and thought he could clear up the matter later. One of the detectives, the only witness for the state, provided vague and contradictory testimony. The detective said he could not recall whether he threatened Taylor or if Taylor asked for a lawyer. The attorney’s testimony corroborated Taylor’s version of events. The court denied Taylor’s motion to suppress. The jury convicted Taylor, and he appealed. While incarcerated, Taylor petitioned for a writ of habeas corpus in federal district court against Thomas Maddox (defendant) under the Federal Anti-Terrorism and Effective Death Penalty Act of 1996 (AEDPA). The district court denied Taylor’s petition. Taylor appealed.