---
title: Taylor v. State
collection: opinions
id: S24A1065
cite_as: Taylor v. State, 320 Ga. 555 (2024)
canonical_url: https://georgiacommons.org/opinions/S24A1065
md_url: https://georgiacommons.org/opinions/S24A1065.md
text_url: https://georgiacommons.org/opinions/S24A1065/text
source_url: https://www.courtlistener.com/opinion/10680190/taylor-v-state/
date: 2024-12-20
status: published
corpus_version: opinions-2026-09-14
license: Public record of the Supreme Court of Georgia, via CourtListener and the court's own website; see about.md
publisher: Georgia Commons, an independent project of Georgia Civic Data. Not the State of Georgia. Not legal advice.
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omitted: opinion extras
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docket: S24A1065
citation: 320 Ga. 555
court: Supreme Court of Georgia
case_type: criminal appeal
authoring_justice: LaGrua
disposition: Affirmed
vote: All the Justices concur
word_count: 730
date_filed_source: courtlistener
citations:
  - 910 S.E.2d 554
record_source: courtlistener
legal_areas:
  - criminal law
  - constitutional law
upstream_id: "10680190"
summaries_model: claude-sonnet-5
---

# Taylor v. State

Supreme Court of Georgia, docket S24A1065, filed 2024-12-20, 320 Ga. 555.

## Opinion

320 Ga. 555 FINAL COPY

S24A1065. TAYLOR v. THE STATE.

LAGRUA, Justice.

In 1999, Appellant Matthew Taylor was convicted of felony murder and related crimes in connection with the death of Terry Hall and was sentenced to life in prison. This Court affirmed Taylor’s convictions and sentence on direct appeal in Rittenhouse v. State, 272 Ga. 78 (526 SE2d 342) (2000).1 More than 23 years later, on December 7, 2023, Taylor returned to the trial court pro se and filed an “Extraordinary Motion for New Trial Pursuant to Criminal Trial Ending in ‘Mutually Exclusive Jury Verdict,’” raising state and federal constitutional claims of trial court error and ineffective assistance of counsel arising from his 1999 criminal trial. The trial court dismissed Taylor’s motion, and Taylor now appeals. For the reasons explained herein, we affirm the trial court’s order of

1 Taylor’s direct appeal was consolidated with the direct appeal of his co- defendant Jerry Rittenhouse. See Rittenhouse, 272 Ga. at 78 n.1. dismissal on grounds other than those relied upon by the trial court.

Taylor’s extraordinary motion maintained that the trial court erred by accepting jury verdicts which he argued were mutually exclusive, that the trial court erred at sentencing by imposing a sentence based on those verdicts, and that his trial counsel was ineffective by failing to object to a sentence predicated on those verdicts. Taylor contends that these alleged errors, along with the ineffectiveness of his trial counsel, deprived him of his rights to due process, equal protection, and to a jury trial under the Georgia Constitution, along with rights afforded to him under the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution.

The problem for Taylor is that constitutional claims cannot be raised in an extraordinary motion for new trial. Instead, the exclusive post-appeal procedure for constitutional claims — like those raised by Taylor here — lies in habeas corpus. See Smith v. State, 276 Ga. 14, 15 (1) (573 SE2d 64) (2002) (“Habeas corpus is the exclusive post-appeal procedure available to a criminal defendant

who asserts the denial of a constitutional right.”) (citations omitted), disapproved on other grounds by Wilkes v. Terry, 290 Ga. 54 (717 SE2d 644) (2011); Mitchum v. State, 306 Ga. 878, 884-885 (1) (c) (834 SE2d 65) (2019) (explaining post-appeal constitutional claims are “not properly raised” in an extraordinary motion for new trial and reaffirming that “constitutional matters that are exclusively governed by the adequate remedy of habeas corpus cannot be pursued through [an extraordinary motion for new trial]”) (footnote omitted). Accordingly, we express no opinion as to the viability of Taylor’s claims because he has used the wrong vehicle to pursue them. And, when such claims are improperly raised in an extraordinary motion for new trial, the only appropriate action is to dismiss the motion. See, e.g., Chaney v. State, 317 Ga. 181 (891 SE2d 775) (2023) (affirming dismissal of extraordinary motion for new trial where defendant raised only ineffective assistance of counsel claims because an adequate alternative remedy existed in the form of habeas corpus) (citing Mitchum, 306 Ga. at 887 (2)).2 In sum, because Taylor’s direct appeal has concluded, see Rittenhouse, 272 Ga. at 79 (1), the constitutional claims that he seeks to raise here are governed exclusively by habeas corpus and are not properly presented in an extraordinary motion for new trial. See Mitchum, 306 Ga. at 884-885 (1) (c); Smith, 276 Ga. at 15 (1).

While the trial court should have dismissed on this basis, we do not fault its attempt to construe Taylor’s unclear filing by “look[ing] to substance over form.” Waye v. State, 239 Ga. 871, 875 (1) (238 SE2d 923) (1977). Notwithstanding any error in the trial court’s construction of Taylor’s extraordinary motion, the correct outcome was reached by dismissing it. We therefore affirm the trial court’s order dismissing Taylor’s extraordinary motion for new trial.

Judgment affirmed. All the Justices concur.

2 That Taylor may face steep procedural hurdles in a habeas proceeding does not mean his claims can properly be raised in an extraordinary motion for new trial.

Decided December 20, 2024.

Murder. Floyd Superior Court. Before Judge Sparks.

Matthew A. Taylor, pro se.

Leigh E. Patterson, District Attorney, Elisabeth M. Giuliani, Assistant District Attorney; Christopher M. Carr, Attorney General, Beth A. Burton, Deputy Attorney General, Clint C. Malcolm, Matthew B. Crowder, Meghan H. Hill, Senior Assistant Attorneys General, for appellee.

## Summaries written by Georgia Commons

The following was written by claude-sonnet-5 from the opinion above and is not part of the court's opinion. Quote the opinion, not the summary.

The Supreme Court of Georgia upheld the dismissal of a man's decades-later bid for a new trial in his 1999 murder case, ruling that constitutional claims like his must be raised through habeas corpus, not an extraordinary motion for new trial.

### Plain-language summary

Matthew Taylor was convicted of felony murder in 1999 in connection with the death of Terry Hall, and the Supreme Court of Georgia affirmed his conviction on direct appeal that same year. More than 23 years later, Taylor, representing himself, filed an extraordinary motion for new trial in the trial court, arguing that the jury verdicts against him were legally inconsistent, that his sentence was based on those flawed verdicts, and that his trial lawyer failed to object to the sentence. He framed these claims as violations of his state and federal constitutional rights.
The trial court dismissed his motion, and Taylor appealed. The Supreme Court of Georgia agreed the motion should be dismissed, but for a different reason than the trial court gave. The court explained that constitutional claims like Taylor's can only be pursued through a habeas corpus proceeding, a separate legal challenge to the legality of someone's imprisonment, once a direct appeal is over. Because Taylor used the wrong legal tool, the court affirmed the dismissal without weighing in on whether his underlying claims have merit.

### Holding, as summarized

Constitutional claims raised after a direct appeal has concluded, including claims of trial court error and ineffective assistance of counsel, must be pursued exclusively through habeas corpus, not through an extraordinary motion for new trial, so dismissal of Taylor's motion was correct even though the trial court gave a different reason.

### Disposition

Affirmed. All the Justices concur.

### Why it matters

The ruling reinforces that Georgia defendants whose direct appeals have concluded cannot revive constitutional challenges through extraordinary motions for new trial years later; they must use habeas corpus instead, which carries its own strict procedural deadlines and hurdles that can make relief harder to obtain.

> The summarized reasoning, checked quotes, suggested questions, and the CourtListener opinion records (1,700 characters) are at https://georgiacommons.org/opinions/S24A1065.md?full=1