Facts
- Air Force Second Lieutenant Daniel Taylor was facing accusations that he had counterfeited U.S. currency.
- While under suspicion, Taylor sent letters to family members and several officials stating that he was contemplating suicide.
- A few days later, a park ranger found an inflatable kayak containing Taylor’s wallet, a spent shell casing, and blood smears.
- Authorities concluded the kayak scene was staged to create the appearance that Taylor had died by suicide.
- Taylor was arrested alive about one month later.
- After his arrest, investigators found evidence that Taylor had forged numerous documents intended to create a new identity.
- Months before the staged kayak scene, Taylor had downloaded two articles about changing one’s identity and how to “get lost and stay lost.”
- At a general court-martial, Taylor was convicted of desertion, multiple forgery-related offenses, and larceny.
- Taylor appealed his convictions to the United States Air Force Court of Criminal Appeals.
Issues
- Whether the evidence was legally and factually sufficient to support Taylor’s desertion conviction, including proof of intent to remain away permanently, based on circumstantial evidence such as the staged suicide scene and identity-creation efforts.
- Whether the evidence was legally and factually sufficient to support the forgery-related convictions and the larceny conviction.
- Whether evidence of Taylor’s preparatory conduct (including downloaded “how to disappear” materials and related actions) could properly be used to show intent for the charged offenses.
Decision
- The United States Air Force Court of Criminal Appeals issued an unpublished opinion in United States v. Taylor, 2006 WL 521595 (2006), addressing Taylor’s appeal from his general court-martial convictions.
- Publicly available sources identify the case, parties, court, and core facts, but they do not provide access to the opinion’s full text; therefore, the specific holdings and the precise disposition (for example, whether findings and sentence were affirmed in full or modified) cannot be stated reliably from open materials.
Legal Principles
- Under Article 66 review, a service court of criminal appeals reviews legal sufficiency and also conducts an independent factual sufficiency review of court-martial findings.
- Desertion requires an unauthorized absence and proof of the accused’s intent (commonly, intent to remain away permanently), which may be proven by circumstantial evidence.
- Conduct suggesting flight, concealment, or planning to avoid detection—such as staging a death scene or preparing to assume a new identity—may be considered when assessing intent.
- Forgery-related offenses require proof of the charged false making or use of documents, along with the required intent to defraud; intent may be inferred from surrounding circumstances.
- Larceny requires proof of a taking or wrongful obtaining of property with intent to permanently deprive; circumstantial evidence may establish the mental state.
Conclusion
United States v. Taylor, 2006 WL 521595 (A.F. Ct. Crim. App. 2006) concerns Second Lieutenant Daniel Taylor’s appeal from general court-martial convictions for desertion, forgery-related offenses, and larceny, where the prosecution relied heavily on circumstantial proof that Taylor staged an apparent suicide and prepared forged documentation to live under a new identity; because the unpublished opinion text is not available in open sources, the court’s exact resolution and disposition cannot be summarized beyond that the AFCCA decided the appeal.