State of Maine v. Chad A. Logan, 2014 ME 92

On Dec. 25–26, 2012, Chad A. Logan (the uncle) was alleged to have touched his nieces E.L. (11) and C.L. (13) sexually and kissed them on the mouth while at their father’s apartment. Victims later disclosed the conduct to their mother and police.
Logan was indicted on one count of unlawful sexual contact (Class B), one count of unlawful sexual touching (Class D), and two counts of assault (Class D). He was tried by jury and convicted on all counts.
At trial Logan sought to cross-examine the victims’ mother about her own childhood sexual abuse to show she was hypersensitive and may have influenced the girls; the court limited questioning to the mother’s general hypervigilance and excluded the abuse history.
A recorded police interview of Logan was played with agreed redactions; due to timing error a fragment including the phrase “no reason to lie” was inadvertently audible to the jury. Logan moved for a mistrial; the court denied it and gave a curative instruction.
After defense testimony revealed Logan worked at Bath Iron Works, the court learned the jury foreperson also worked there; neither recognized the other and defense did not request removal or further inquiry.
Logan appealed, arguing exclusion of the mother’s abuse history, denial of mistrial, failure to excuse/inquire the juror, and insufficiency of the evidence. The court affirmed the convictions.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Logan)	Held
Admissibility of mother’s childhood sexual-abuse history on cross-examination	Exclusion permissible as the specific abuse history was not relevant to victims’ credibility	The mother’s abuse history was relevant to show hypersensitivity and that she shaped daughters’ perceptions	Court: Exclusion not clearly erroneous; general testimony on mother’s hypervigilance sufficient; no prejudice because the interview alluded to the history
Motion for mistrial after inadvertent playback of "no reason to lie"	The fragment was not highly prejudicial; curative instruction adequate	The phrase prejudiced jury by implying victim credibility	Court: Denial of mistrial not an abuse of discretion; curative instruction cured any potential prejudice
Failure to excuse or further inquire of juror who worked at same company as defendant	Juror impartiality preserved; no showing of actual bias	Juror employment created potential bias requiring further inquiry or removal	Court: Reviewed for obvious error; no error—juror and defendant did not know each other and defense made no request for removal or inquiry
Sufficiency of the evidence to support convictions	Victims’ testimony supported each element; jury credited testimony	Victims’ memory lapses undermined reliability and sufficiency	Court: Viewed in State’s favor, testimony addressed elements and was not inherently incredible; convictions upheld

State v. Mills, 910 A.2d 1053 (Me. 2006) (limits on cross-examination and relevance review)
State v. Dolloff, 58 A.3d 1032 (Me. 2012) (standards for relevance and evidentiary rulings)
State v. Poblete, 993 A.2d 1104 (Me. 2010) (mistrial standard; trial court discretion reviewed for abuse)
State v. Nelson, 994 A.2d 808 (Me. 2010) (effectiveness of curative instructions for extraneous evidence)
State v. Rollins, 961 A.2d 546 (Me. 2008) (procedures for questioning juror impartiality)
State v. Moores, 910 A.2d 373 (Me. 2006) (victim testimony alone can support sex-crime conviction if not inherently incredible)
State v. Williams, 52 A.3d 911 (Me. 2012) (viewing evidence in light most favorable to the State)