Pearson v. State, 86 A.3d 1232

Pearson was tried in Baltimore City for drug offenses; all State witnesses were Baltimore City police officers and an expert chemist.
Before trial, Pearson’s co-defendant proposed voir dire questions asking whether jurors (1) had ever been crime victims, (2) knew anyone in law enforcement or prosecutors, or (3) had ever been members of law enforcement; the trial court declined to ask them.
The court did ask (a) whether any juror had such strong feelings about narcotics law violations that they could not be fair, and (b) whether jurors would give more or less weight to police testimony solely because the witness was a police officer.
Pearson was convicted; the Court of Special Appeals affirmed. This Court granted certiorari to decide whether trial courts must ask (on request) the two contested voir dire questions.
The Court reviewed Maryland’s limited-voir-dire doctrine: voir dire exists only to uncover specific cause for disqualification, not to aid peremptory challenges.
The Court held (1) on request the trial court need not ask whether jurors have ever been crime victims but must ask, on request, the narrower question “Do any of you have strong feelings about [the crime charged]?” and (2) where all (or key) State witnesses are law-enforcement officers, on request the trial court must ask, “Have any of you ever been a member of a law enforcement agency?” Remand for a new trial.

Issue	Plaintiff's Argument (Pearson)	Defendant's Argument (State)	Held
Whether trial court must ask if any prospective juror has ever been a crime victim	The question likely reveals specific cause for disqualification or helps exercise peremptories	Not reasonably likely to reveal cause; existing "strong feelings" question suffices; voir dire shouldn’t facilitate peremptory strategy	No—court need not ask victim status; but must (on request) ask the narrower "Do any of you have strong feelings about [the crime charged]?"; trial court misstated Shim’s formulation and must use the corrected phrasing
Whether trial court must ask if any prospective juror has been a member of law enforcement	Such membership is reasonably likely to reveal specific cause for disqualification when police testimony is central	Not likely to reveal cause; undue-weight question suffices	Yes—where all or the key witnesses are law-enforcement members, on request the court must ask: "Have any of you ever been a member of a law enforcement agency?" (Davis limited/overruled on this point)

Moore v. State, 412 Md. 635 (establishes that a voir dire question must be reasonably likely to reveal specific cause for disqualification)
Washington v. State, 425 Md. 306 (explains Maryland’s limited-voir-dire purpose—discovering cause for disqualification, not aiding peremptory strikes)
Curtin v. State, 393 Md. 593 (requires demonstrably strong correlation between a juror’s status/experience and a mental state giving rise to disqualification)
Dingle v. State, 361 Md. 1 (prohibits compound voir dire questions that shift to jurors the court’s duty to assess bias)
State v. Shim, 418 Md. 37 (required a "strong feelings" question; Court narrows its phrasing here to avoid shifting bias assessment to jurors)
Davis v. State, 333 Md. 27 (previously permitted refusal to ask about law-enforcement association; Court limits/overrules this holding as to juror membership when police testimony is central)
Perry v. State, 344 Md. 204 (refused broad victim-related voir dire as unlikely to reveal disqualification and warned about time/resource burdens)
Yopps v. State, 234 Md. 216 (held asking whether jurors had been burglary victims was not reasonably likely to reveal disqualification)
State v. Thomas, 369 Md. 202 (discusses when courts must inquire into experiences, status, or affiliations)
Sweet v. State, 371 Md. 1 (supports asking narrow "strong feelings" questions about particular charges)