Benton v. State
121 A.3d 246
Md. Ct. Spec. App.2015Background
- Joshua Benton was convicted in Prince George’s County Circuit Court of first-degree murder, conspiracy to commit first-degree murder, and handgun use, receiving consecutive life sentences and a 20-year term.
- The State alleged Benton and co-defendant Lawson killed Sharod James at a gas station to avenge a friend’s death.
- Two eyewitnesses saw two men near the body; their clothing matched Benton and Lawson in surveillance footage.
- Evidence included a phone call to James from Lawson’s number and jailhouse testimony that Benton admitted being at the gas station the night of the shooting.
- Benton challenged voir dire, hearsay, and sufficiency of the evidence, arguing the trial court failed to ask a crucial disqualification voir dire question.
- The Court of Special Appeals reversed and remanded for a new trial due to reversible error in voir dire, while addressing other issues accordingly.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court failed to propound the requested voir dire on disqualifications | Benton | State | Reversible error; convictions reversed and remanded |
| Admission of informant’s testimony as hearsay or lay opinion | Benton | State | Harmless error beyond a reasonable doubt |
| Sufficiency of the evidence to support the convictions | Benton | State | Evidence sufficient to sustain convictions |
Key Cases Cited
- Pearson v. State, 437 Md. 350 (Md. 2014) (limited voir dire to expose disqualifications; overbroad questions may be refused but essential disqualification inquiries must be asked)
- Owens v. State, 399 Md. 388 (Md. 2007) (mandatory voir dire on minimum qualifications; pre-voir dire screening not fail-safe)
- Kegarise v. State, 211 Md. App. 473 (Md. Ct. App. 2013) (reversible error for failing to pose citizenship disqualification question)
- Baker v. State, 157 Md. App. 600 (Md. Ct. App. 2004) (preservation of voir dire objections under Rule 4-323(c))
- Moore v. State, 412 Md. 635 (Md. 2010) (limits on trial court’s voir dire regarding statutory disqualifications)
- Washington v. State, 425 Md. 306 (Md. 2012) (limits of limited voir dire for disqualification inquiries)
- Yates v. State, 429 Md. 112 (Md. 2012) (admissibility of substantially established testimony despite objections)
- Davis v. State, 333 Md. 27 (Md. 1993) (principles on admissibility and relevance in voir dire context)