Taylor v. United States

Background

A man was on trial for four counts of selling cocaine. He attended the morning session, was told by his lawyer to return after lunch, and did not come back that afternoon or the next morning. His wife testified they had separated after the morning session and that she had not heard from him since. The defense asked for a mistrial, saying the jury might be tainted and that the defendant could not confront witnesses. The judge found that he had voluntarily absented himself, told the jury not to draw guilt from his absence, and the jury found him guilty on all counts. He was later arrested and given the statutory five-year minimum sentence. The Court of Appeals affirmed, and this Court also affirmed.

Reasoning

The central question was whether a trial may lawfully continue when a defendant voluntarily leaves and whether the court must give a special warning that the trial will go on without him. The Court relied on Federal Rule of Criminal Procedure 43 and long-standing precedent, especially Diaz v. United States, to say the Rule reflects the established rule that voluntary absence operates as a waiver of the right to be present. The Court rejected the idea that the judge had to expressly warn the defendant that the trial would proceed and thus foreclose his right to testify or confront witnesses. The Court emphasized the defendant was at liberty on bail, had attended the trial, and gave no account claiming ignorance of the consequences.

Real world impact

The decision confirms that when a defendant freely leaves a noncapital trial, courts may continue and verdicts can stand. It upholds Rule 43 and does not find any constitutional violation in these circumstances.