by Free Taylor Project | May 12, 2020 | Legal
GROUNDS FOR RELIEF CHARGING THE CRIME OF AGGRAVATED FIRST DEGREE MURDER OR IN THE ALTERNATIVE FIRST DEGREE FELONY MURDER IN THIS CASE IS UNCONSTITUTIONAL IN PART BECAUSE THERE IS NO SUCH CRIME AS “AGGRAVATED FIRST DEGREE MURDER” AND CHARGING PREMEDITATED MURDER...
by Free Taylor Project | May 12, 2020 | Legal
GROUNDS FOR RELIEF PETITIONER’S UNDERLYING HEREIN CHALLENGED CONVICTION AND SENTENCE UNDER RCW 10.95.020 IS “VOID FOR VAGUENESS” BASED ON THE STATE OF WASHINGTON COURTS’ DECISIONAL LAW CREATING ARBITRARY AND DISCRIMINATORY STANDARDLESS ENFORCEMENT RESULTING IN...
by Free Taylor Project | May 12, 2020 | Legal
GROUNDS FOR RELIEF NO EVIDENCE DOCTRINE: THE TRIAL JUDGE MADE AN IMPROPER COMMENT ON THE EVIDENCE BY INSTRUCTING THE JURY THAT AS MATTER OF LAW HE HAD MADE AND INITIAL DETERMINATION THAT ALL EVIDENCE INTRODUCED AT TRIAL HAD MET HIS THRESHOLD STANDARD OF...
by Free Taylor Project | May 12, 2020 | Legal
GROUNDS FOR RELIEF THE ACCOMPLICE LIABILITY JURY INSTRUCTION GIVEN TO THE JURY IN THIS CASE RCW 9A.080.020 (3) (a) AND OTHER ACCOMPLICE LIABILITY INSTRUCTIONS ARE NOT APPLICABLE TO RCW 10.95.020 AND/OR RCW 9A.32.030 (1) (a) COMPOUNDED BY THE SEVERE LEGAL...
by Free Taylor Project | May 12, 2020 | Legal
GROUNDS FOR RELIEF THE SUBSTANTIVE JURY INSTRUCTIONS GIVEN TO THE JURY IN THIS CASE HAD THE LEGAL FORCE AND EFFECT OF SYSTEMATIC EROSION OF STATE’S BURDEN OF PROOF BEYOND A REASONABLE DOUBT OF EACH FACT NECESSARY TO CONSTITUTE ELEMENTS OF EACH CRIME CHARGED...
by Free Taylor Project | May 12, 2020 | Legal
GROUNDS FOR RELIEF THE DEFENDANT-PETITIONER WAS TRIED AND CONVICTED OF MURDER IN THE FIRST DEGREE PREMISED ON TWO ALTERNATIVE SEPARATE AND DISTINCT CRIMES RCW 9A.32.020 (1) (a) AND RCW 9A.32.030 (1) (c) IN A SINGE COUNT OF THE INFORMATION WHICH IS LEGALLY...