## Facts

- Lamar Railey was struck by an accelerating vehicle while walking in a parking lot after closing his business and going to purchase fuel.
- A bystander called 911 and followed the fleeing vehicle until police stopped it and arrested the driver, Zachary Bouvier Taylor.
- Officers searched Taylor’s vehicle and found a manila envelope bearing Railey’s name containing documents from a civil dispute between Taylor and Railey, including pleadings and an affidavit Taylor drafted to seek an arrest warrant for Railey.
- The State offered the civil-dispute documents to show Taylor’s animus toward Railey and to support motive and intent, not to prove the truth of the allegations in the documents.
- Railey suffered serious injuries, including leg fractures and bruising, was hospitalized, and later died 16 days after the collision.
- Medical testimony attributed Railey’s death to pulmonary thromboemboli (blood clots) caused by the leg injuries and resulting immobility from the vehicle strike.
- A jury convicted Taylor of malice murder and aggravated battery; the trial court imposed life imprisonment for malice murder plus 20 years for aggravated battery.
- Taylor’s motion for new trial was denied, and he appealed.

## Issues

1. Whether the trial court erred by admitting civil-suit pleadings and related documents involving Taylor and the victim, given the general privilege associated with allegations in judicial pleadings.
2. Whether the evidence was sufficient to prove beyond a reasonable doubt (a) malice for malice murder (including implied malice) and (b) that Taylor’s act was the efficient, proximate cause of Railey’s death.

## Decision

- The Supreme Court of Georgia affirmed the convictions and sentence.
- The court held the civil-suit pleadings and related documents were admissible to show motive and state of mind and were not used to establish the truth of the allegations.
- The court held the evidence permitted a rational jury to find implied malice from Taylor’s conduct and surrounding circumstances.
- The court held the medical evidence supported a finding that the collision injuries were the efficient, proximate cause of death, with no independent intervening cause breaking the causal chain.
- Applying the standard for sufficiency review, the court concluded the evidence supported the verdict.

## Legal Principles

- Malice for malice murder may be proven by express malice or implied malice; implied malice may be inferred when circumstances show an abandoned and malignant heart and no considerable provocation.
- A jury may infer intent where the defendant’s conduct is substantially certain to cause death or serious bodily harm, even if the defendant claims not to have desired the result.
- The litigation privilege that shields pleadings from serving as a basis for civil liability does not bar their admission in a criminal trial when offered for a non-hearsay purpose such as motive, animus, or state of mind.
- Proximate cause is satisfied where the defendant’s act sets in motion a natural and continuous sequence leading to death, and death results without an independent, intervening cause.
- On appellate review of evidentiary sufficiency, the evidence is viewed in the light most favorable to the verdict; the question is whether a rational trier of fact could find guilt beyond a reasonable doubt.

## Conclusion

The court upheld the admission of civil-dispute documents to show Taylor’s motive and intent, and it concluded the evidence supported implied malice and a finding that injuries from the vehicle strike proximately caused the victim’s death, warranting affirmance of the malice murder and aggravated battery convictions.


Taylor v. State, 282 Ga. 44, 644 S.E.2d 850 (Ga. 2007)