Trotman v. State, 218 A.3d 265

Defendant Danny Trotman (correctional officer) was tried in Baltimore City Circuit Court for second‑degree assault and related charges; convicted by a jury and sentenced.
Four prospective jurors disclosed they could not or would have difficulty using stairs; the courthouse jury room for the assigned courtroom was reachable only via a 25‑step staircase (no elevator).
The trial judge individually questioned each juror at the bench, confirmed their inability to use the stairs, excused each for cause, and directed them to return to the jury assembly room for potential service on other panels.
Defense counsel objected and requested switching to a different courtroom or other accommodations; the judge found no other courtroom was available and proceeded with voir dire and trial.
The Court of Special Appeals affirmed; the Court of Appeals granted certiorari limited to whether excusing the jurors for cause was proper under the ADA and Maryland law, and affirmed the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a trial court may summarily excuse prospective jurors with disabilities without considering accommodations	Trotman: trial court failed to exercise discretion and did not adequately consider or investigate reasonable accommodations (e.g., another courtroom, alternative jury room)	State: a trial court may excuse a juror for cause if the disability would prevent satisfactory service and accommodations are not practicable; here the judge found no available alternative courtroom	A trial court may not summarily excuse jurors with disabilities; it must conduct an individualized, case‑and‑disability‑specific inquiry and only excuse if no reasonable accommodation is possible and the disability prevents satisfactory jury service. Applying that rule, the court did not abuse its discretion in excusing the four jurors where a 25‑step access was unavoidable and no alternative was available.

Batson v. Kentucky, 476 U.S. 79 (1986) (established three‑step test for discrimination challenges to peremptory strikes based on race)
J.E.B. v. Alabama ex rel. T.B., 511 U.S. 127 (1994) (Equal Protection prohibits intentional gender‑based jury discrimination)
Bd. of Trs. of Univ. of Ala. v. Garrett, 531 U.S. 356 (2001) (States not required by Fourteenth Amendment to make special accommodations for disabilities absent statutory mandate)
Tennessee v. Lane, 541 U.S. 509 (2004) (ADA enforcement of Fourteenth Amendment rights valid for cases implicating fundamental access to courts)
United States v. Harris, 197 F.3d 870 (7th Cir. 1999) (peremptory strike of a juror with MS did not violate Equal Protection where disability could impair juror attention)
United States v. Santiago‑Martinez, 58 F.3d 422 (9th Cir. 1995) (Batson does not prohibit peremptory strikes for certain physical traits like obesity)
People v. Guzman, 555 N.E.2d 259 (N.Y. 1990) (deaf juror assisted by interpreter can properly serve; disability alone does not disqualify)
People v. Falkenstein, 732 N.Y.S.2d 817 (N.Y. App. Div. 2001) (peremptory strike of a hard‑of‑hearing juror permissible where hearing impairment could affect evaluation of audiotape evidence)
Donelson v. Fritz, 70 P.3d 539 (Colo. App. 2002) (upheld exclusion of jurors with disabilities in tort case where disability similarity could affect sympathy or attention)