State v. Holm, 402 P.3d 193

Early-morning collision: Holm ran a red light, struck an oncoming vehicle, and the passenger (Victim) died; Holm was charged with negligent homicide (class A misdemeanor) and tried by jury.
During voir dire, the court asked whether jurors had been in a serious car accident; ~1/3 said yes.
Holm requested individual follow-up questioning of jurors who had personal or close-person experience with serious car accidents; the court limited questioning to those who said the experience might bias them.
Most jurors seated had indicated such experience but were not individually questioned about details; only four indicated possible bias and were removed or otherwise did not serve.
Jury convicted Holm; he appealed arguing the court abused its discretion by denying broader individual voir dire, impairing his ability to exercise peremptory challenges.

Issue	Holm's Argument	State's Argument	Held
Whether the trial court abused its discretion by denying Holm the opportunity to individually voir dire jurors who said they or someone close had been in a serious car accident	Holm argued follow-up questions were necessary to expose actual or potential bias and to inform peremptory-challenge decisions	State argued the court reasonably limited questioning to those who expressed that the experience might affect impartiality to avoid overbroad, burdensome inquiry	Court held the trial court exceeded its discretion; follow-up questioning was required because the topic was directly related to the offense and bore on actual bias and peremptory challenges

State v. Reece, 349 P.3d 712 (Utah 2015) (trial courts generally should be permissive in allowing voir dire and must allow inquiries that go directly to actual bias)
State v. Saunders, 992 P.2d 951 (Utah 1999) (limitations on voir dire disallowed when questions have an apparent link to potential bias)
State v. King, 190 P.3d 1283 (Utah 2008) (jurors’ statements that they or someone close were victims of similar offenses suggest potential bias)
State v. King, 131 P.3d 202 (Utah 2006) (similar: such disclosures support counsel’s request for additional questioning)
Alcazar v. Univ. of Utah Hosps. & Clinics, 188 P.3d 490 (Utah Ct. App. 2008) (error in limiting voir dire requires showing of prejudicial impairment to peremptory challenges)
Barrett v. Peterson, 868 P.2d 96 (Utah Ct. App. 1993) (prejudicial error shown if informed exercise of peremptory challenges was substantially impaired)
State v. Ball, 685 P.2d 1055 (Utah 1984) (jurors often cannot recognize or disclose their own prejudices; courts should probe potential bias)