Thomas v. State, 165 A.3d 368

Appellant Thomas was tried for robbery and related offenses after an armed robbery; two police officers and a detective were expected to testify.
During pretrial voir dire both parties requested a specific police-witness occupational-bias question asking whether jurors would give greater weight to testimony of law enforcement because of their occupation.
The trial judge declined to ask the short, occupation-specific question and instead delivered a lengthy, generalized occupational-bias monologue that listed many occupations (physician, clergyman, firefighter, police officer, etc.).
No venireperson responded affirmatively to the judge’s broad question; the judge later questioned those who had responded to other voir dire topics at sidebar and empaneled the jury.
Appellant was convicted; the Court of Special Appeals certified a question to the Court of Appeals about whether a broader occupational-bias question suffices when counsel requested a police-witness question.
The Court of Appeals answered no: when requested, the judge must tailor the occupational-bias question to the specific occupations of witnesses expected to testify (here, police officers).

Issue	Plaintiff's Argument (Thomas)	Defendant's Argument (State)	Held
Whether a trial judge may satisfy a requested police-witness voir dire by asking a broader occupational-bias question that names many occupations	The judge’s 450-word, 30-sentence question obscured the police-witness inquiry and failed to elicit the specific bias the requested question would reveal	The judge’s explanation of credibility and inclusion of "police officer" in the list was adequate to probe bias; the broader question followed Moore and was not confusing	The Court held the broader formulation was insufficient; when police witnesses will testify and counsel requests the police-witness question, the voir dire must be tailored to that occupation

Moore v. State, 412 Md. 635, 989 A.2d 1150 (occupational-bias inquiry extends beyond police and must be tailored to occupations of testifying witnesses)
Langley v. State, 281 Md. 337, 378 A.2d 1338 (police-witness question required when police will testify because juror predisposition to favor police is disqualifying)
Bowie v. State, 324 Md. 1, 595 A.2d 448 (applies Langley; police-witness question protects against prejudgment based on official status)
Pearson v. State, 437 Md. 350, 86 A.3d 1232 (discusses scope of voir dire and when certain questions must be asked)
Wright v. State, 411 Md. 503, 983 A.2d 519 (voir dire abuse where many questions were asked without allowing timely responses)
Dingle v. State, 361 Md. 1, 759 A.2d 819 (abuse where compound questions shifted judge’s responsibility to venire and impeded discovery of bias)