Case No. 1163148 – Harless A.


The Complainant in this case was the 15-year-old stepdaughter of our client, Harless. Complainant had a history of mental disturbance. Prior to the alleged molestation she had shown many well-documented behavioral anomalies indicating mental illness. This, combined with adroit lying and sexual precocity, led her to vow to get her stepfather “out of the house” – which her own mother testified to as a witness. Harless had become the default disciplinarian – but a good one – due to diabetes which prevented him from working while his wife, Complainant’s mother, was away working long hours. The triggering incident was Harless’ appropriate confiscation of Complainant’s cell phone for repeated violations of its rules of use. Complainant immediately fabricated an outlandish story but shot herself in the foot by making the date of the alleged assault several weeks prior to her outcry.

Our vigorous defense included documenting several incidents proving Complainant’s modus operandi of making allegations of sexual abuse for various ulterior motives such as accusing a classmate of sexual harassment because she was angry at him and a separate claim of rape by another Defendant during the pendency of this case. The officer who took the report of this rape was a very good witness for us – he stated he “didn’t quite believe her”. The time lag between the alleged molestation and the outcry to school counselors was significant. CPS got involved and polygraph tests were taken by our client and Complainant. We interviewed witnesses and reviewed all CPS and police video and audio statements. Other evidence which helped our case was irrefutable documentation of Complainant’s story changes on this and the rape incident. As one witness put it and as Mr. Haggard so ably proved, in getting her stepfather arrested she “acted as if she had won a game” – a game that she was playing with everyone’s lives. In several meetings with Prosecutors we put together a compelling presentation of the evidence in favor of our client’s innocence. Mr. Haggard moved to get this case before the Grand Jury as soon as feasible and obtained a No-Bill prior to setting the case for Trial.