State v. Leon, 186 A.3d 129

Defendant Peter W. Leon was tried and convicted by a jury of Class D assault for touching a 15‑year‑old victim's back and making a comment; surveillance video and witness testimony were admitted.
After the guilty verdict was announced and the jury discharged for the night, one juror told a judicial marshal she had "gone against all of her morals" and felt pressured by other jurors to return a guilty verdict; she did not report this to the court that night.
The next morning the court disclosed the marshal’s report to the parties; the State argued the report could not affect the verdict and the court concluded there was no juror misconduct.
Leon requested a continuance to research the issue before sentencing; the court denied the continuance, proceeded to sentencing, and imposed the statutory penalties (fine and suspended jail term with conditions).
On appeal Leon argued the juror’s statement showed coercion and denied him a fair trial; he also raised (for the first time) claims that a jury instruction on "offensive physical contact" was incorrect and that the court should have instructed on the bodily‑injury variant of assault.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether post‑verdict juror statement that she felt pressured can impeach the verdict	Leon: juror’s statement to marshal shows coercion, so verdict invalid	State/Court: juror’s statement concerns internal deliberations and is barred from inquiry under M.R. Evid. 606(b) absent external influence or misconduct	Held: barred by Rule 606(b); no evidence of external influence or misconduct, so verdict stands
Whether jury instruction on "offensive physical contact" was incorrect or court should have instructed on "bodily injury" variant of assault	Leon: instruction defective and court should have instructed on bodily‑injury alternative	State/Court: instruction correctly defined offensive physical contact; evidence did not support bodily‑injury theory so no instruction required	Held: instructions proper; no error in declining to instruct on bodily‑injury variant
Whether marshal intimidated jurors during trial	Leon: marshal’s conduct intimidated jurors	State/Court: no record evidence of intimidation; claim raised for first time on appeal	Held: no record support; claim rejected

Patterson v. Rossignol, 245 A.2d 852 (Me. 1968) (establishes rule barring juror testimony to impeach verdict and lists policy rationales)
Ma v. Bryan, 997 A.2d 755 (Me. 2010) (applies Rule 606(b) and limits inquiry to external influences or juror dishonesty on voir dire)
State v. Hurd, 8 A.3d 651 (Me. 2010) (post‑discharge juror communications about deliberations are barred from court consideration)
State v. Watts, 907 A.2d 147 (Me. 2006) (juror change of heart or fear does not permit verdict impeachment)
Cyr v. Michaud, 454 A.2d 1376 (Me. 1983) (discusses codification and rationale for barring juror testimony)
State v. O'Brien, 434 A.2d 9 (Me. 1981) (jury instructions need only address issues generated by the evidence)