State v. Doogan

Mary Ellen Doogan appeals her conviction for second degree promotion of prostitution. Because Doo-gan was denied effective assistance of counsel when her trial attorney proposed — and the jury received — an instruction including an uncharged alternative means, we reverse the conviction and remand for a new trial.

Doogan operated an escort service known as "A Personal Touch.” Two of her employees, Kristin Olson and Rebecca Lund, 1 testified at trial about their work for Doogan and Doogan’s knowledge of the sexual nature of their work. Each testified that she made house calls for A Personal…