## Facts

- Benjamin Matthew Logan was convicted of two counts of first-degree murder for killing two clerks during an armed robbery of a Minneapolis gun store.
- During voir dire, prospective juror K.G. wrote that he would favor police officers’ testimony over other witnesses because it was their job to produce sound evidence.
- K.G. also expressed concern about increased violent crime and stated that this belief would carry “some weight” in deciding guilt, though he would “try” to set it aside.
- In oral questioning, K.G. reiterated a tendency to value police testimony, gave qualified answers about applying the same credibility standards, and repeatedly framed impartiality as trying or doing his best.
- K.G. indicated it would be very difficult for him to conclude a police officer testified falsely; later prosecutor-led questioning elicited only tentative concessions that police could lie and that he thought he could be fair.
- Logan had exhausted all peremptory challenges when he moved to strike K.G. for cause; the trial court denied the challenge.
- K.G. ultimately served as a deliberating juror after becoming a regular juror when another juror became unavailable.
- The trial required jurors to resolve a credibility conflict between a police officer and Logan about statements allegedly made during interrogation.

## Issues

1. Whether the trial court abused its discretion by denying a challenge for cause to a prospective juror who expressed a predisposition to credit police testimony and concern about violent crime.
2. Whether seating that juror, after the defense exhausted peremptory challenges and the juror actually served, violated the defendant’s constitutional right to an impartial jury requiring reversal.

## Decision

- The Minnesota Supreme Court reversed the convictions and remanded for a new trial.
- The court held the trial court abused its discretion by refusing to excuse K.G. for cause because K.G.’s statements showed a continuing, material bias favoring police credibility that he did not unequivocally renounce.
- Because Logan had no peremptory challenges remaining and K.G. served on the jury, the error deprived Logan of the right to a fair trial by an impartial jury.

## Legal Principles

- A juror who has expressed bias may serve only if the juror can set aside that impression and decide the case solely on the evidence and the court’s instructions.
- A juror’s equivocal assurances (e.g., “try,” “probably,” “to the best of my ability,” or “I think I can be fair”) may be insufficient to cure earlier admissions of bias, especially when the juror does not clearly disavow the bias.
- “Rehabilitation” through leading, yes-or-no questions is less persuasive when the juror’s more candid answers indicate partiality.
- When the defense has exhausted peremptory challenges and a juror who should have been excused for cause actually serves, the presence of the biased juror on the panel requires reversal.

## Conclusion

The court ordered a new trial because the seated juror’s unresolved predisposition to believe police testimony, coupled with the defense’s exhausted peremptory challenges and the centrality of police-versus-defendant credibility at trial, violated the right to an impartial jury.


State v. Logan, 535 N.W.2d 320 (Minn. 1995)