Logan v. Gelb, 790 F.3d 65

Logan was convicted in 2007 in Massachusetts state court of living off or sharing the earnings of a minor prostitute, Harriet, age 15 in 2004.
Harriet's age was proven largely through hearsay testimony by a social worker, with defense not objecting at the time.
The conviction was upheld on direct appeal; Logan later moved for a new trial and then filed a federal habeas petition under §2254 in 2013.
The district court denied relief on all claims but issued a certificate of appealability on the argued issues.
The First Circuit reviews under AEDPA deferential standards, reviewing state-court factual findings for correctness and applying de novo review to some legal questions.
Key issues on habeas review include: sufficiency of evidence, hearsay-based proof of Harriet’s minority, and the alleged improper expert testimony by Detective Hall.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Hearsay proof of Harriet's minority	Logan argues due process was violated by relying on hearsay to prove minority.	State contends the claim is unexhausted/waived and that any error is not reversible, with ineffective assistance not saving it.	Waived/unexhausted; claim fails; no prejudice shown.
Sufficiency of the evidence	Logan contends evidence did not prove Harriet engaged in prostitution or transfer of funds to him.	State argues Latimore/Jackson standard satisfied; evidence supports that Harriet prostituted and Logan benefited.	Evidence sufficient; rational jurorcould find elements beyond a reasonable doubt.
Detective Hall's expert testimony	Logan claims Hall relied on hearsay about prostitutes in forming an expert opinion, violating confrontation rights.	State asserts default prevents review; claim not properly raised; no error shown.	Procedural default bars review; no cause shown.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong ineffective assistance standard)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard)
Latimore, 393 N.E.2d 370 (Mass. 1979) (state-law sufficiency standard equivalent to Jackson)
Fortini v. Murphy, 257 F.3d 39 (1st Cir. 2001) (de novo review for federal claims not addressed by state courts)
Gunter v. Maloney, 291 F.3d 74 (1st Cir. 2002) (regularenforcement of claims not raised on appeal; cause and prejudice analysis)
Janosky v. St. Amand, 594 F.3d 39 (1st Cir. 2010) (procedural default and exhaustion requirements)
Rose v. Lundy, 455 U.S. 509 (U.S. 1982) (exhaustion rule and its limits)
Sumner v. Mata, 455 U.S. 591 (U.S. 1982) (AEDPA review framework and deference to state courts)
Scoggins v. Hall, 765 F.3d 53 (1st Cir. 2014) (presumed correctness of state-court factual findings in AEDPA review)
Teague v. Lane, 489 U.S. 288 (U.S. 1989) (limitations on applying new rules in habeas context)