Richard Watson v. State of Maine, 230 A.3d 6

Watson (defendant) was tried and convicted after a two-day jury trial on multiple sexual-offense counts based on allegations by his then-ten-year-old daughter/biological child.
The victim testified at trial describing two incidents from summer 2014; there was no medical, DNA, or eyewitness corroboration—the case was a credibility contest.
After the victim testified, defense counsel offered and played for the jury a 20-minute videotaped police interview of the victim from September 2014 and submitted a transcript for the jury to take into deliberations; the video mirrored the trial testimony and included the interviewing detective’s reassuring/vouching statements.
Defense counsel explained the video was intended to show the victim’s motive to fabricate (custody dispute) and to criticize the State’s investigation; counsel did not recall the victim or otherwise cross-examine her about the interview after it was played.
Watson filed a post-conviction petition claiming ineffective assistance of counsel; the post-conviction court denied relief, but the Maine Supreme Judicial Court granted review on whether playing the interview constituted ineffective assistance.
The Court held defense counsel’s decision to play the entire interview (and give jurors the transcript) was objectively unreasonable and prejudicial in this credibility-driven case, vacating the convictions and remanding to grant the petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel’s playing of the videotaped police interview after the victim testified was objectively unreasonable (performance prong)	Watson: playing the full video (which repeated trial testimony and contained detective vouching) was unnecessary and not sound strategy; it bolstered the victim’s credibility	State/Post-conviction court: counsel reasonably employed a trial strategy to show motive to fabricate and to attack the investigation	Held: Counsel’s conduct was deficient — playing the entire interview (and giving the transcript) was objectively unreasonable
Whether counsel’s deficient performance prejudiced the defense (prejudice prong)	Watson: introduction of the consistent video in a pure credibility case undermined reliability of the verdict and likely affected the outcome	State: verdict shows jurors found the victim credible; no reasonable probability of a different result	Held: Prejudice shown — reasonable probability the outcome would differ; convictions vacated and petition granted

Strickland v. Washington, 466 U.S. 668 (1984) (two-part test for ineffective assistance: performance and prejudice)
State v. Watson, 152 A.3d 152 (Me. 2016) (prior direct-appeal opinion summarizing trial facts)
Ford v. State, 205 A.3d 896 (Me. 2019) (applies Strickland standard; burden and review rules for PCR)
Fahnley v. State, 188 A.3d 871 (Me. 2018) (review of post-conviction factual findings for clear error)
Philbrook v. State, 167 A.3d 1266 (Me. 2017) (prejudice inquiry: conviction unreliable if counsel’s errors undermine confidence in result)
People v. Douglas, 852 N.W.2d 587 (Mich. 2014) (forensic-interview video in a credibility-driven sex-abuse case prejudicial when admitted and permitted repeated testimony)