321 A.3d 116
Md.2024Background
- Charles Mitchell was convicted in Baltimore City Circuit Court of sexual abuse of his minor daughter, with the child's testimony being the State's principal evidence.
- During jury selection (voir dire), defense requested questions aimed at uncovering juror bias regarding the credibility of child-witnesses.
- The trial court only partly granted this request—asking about "concerns" with a child testifying but refusing a more direct question about bias tied to child-witnesses' credibility.
- The Appellate Court of Maryland affirmed the conviction, applying Stewart v. State (2007) as precedent that voir dire need not address child-witness credibility.
- The Supreme Court of Maryland granted certiorari to reconsider Stewart in light of subsequent legal developments and clarify voir dire obligations regarding bias against child-witnesses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Must trial courts inquire into juror bias about child-witnesses' credibility during voir dire when requested? | Mitchell: Required if jurors may prejudge a child’s testimony and the child's testimony is central. | State: Age is rationally related to credibility; such voir dire is not mandated. | YES; must ask a question tailored to uncover bias if the child’s testimony is important to the case. |
| Was Stewart v. State properly superseded by later case law? | Mitchell: Stewart’s narrow reading conflicts with later broader cases on voir dire; should be abrogated. | State: Stewart was not clearly wrong or superseded; later cases are consistent with Stewart. | Stewart’s narrow approach partially abrogated; later law broadened voir dire requirements. |
| Did the trial court properly exercise discretion by only asking about "concerns" over a child testifying? | Mitchell: Insufficient—question must directly probe actual bias regarding credibility. | State: The "concerns" question sufficed to elicit any relevant bias. | NO; asking only about "concerns" was inadequate—the court should have rephrased or supplemented inquiry. |
| Was Mitchell's counsel required to propose a properly worded voir dire question to preserve the issue? | Mitchell: Essence of the bias issue was clear; court had duty to make a proper inquiry. | State: No further clarification or request—no obligation for the court to rephrase. | NO; trial courts must probe for disqualifying bias when the need is made clear, even if counsel's wording is imperfect. |
Key Cases Cited
- Stewart v. State, 399 Md. 146 (Md. 2007) (earlier precedent narrowly rejecting required voir dire on child-witness credibility—now partially abrogated)
- Langley v. State, 281 Md. 337 (Md. 1977) (mandates voir dire on police witness credibility bias)
- Bowie v. State, 324 Md. 1 (Md. 1991) (requires voir dire for bias favoring State or defense witnesses)
- Moore v. State, 412 Md. 635 (Md. 2010) (expands duty to inquire into bias for witness categories beyond just police officers)
- Pearson v. State, 437 Md. 350 (Md. 2014) (standard for when voir dire must reveal disqualifying bias)