Washington v. State
40 A.3d 1017
Md.2012Background
- Washington charged with first degree rape and related offenses in Harford County circa Oct. 26, 2007; he elected trial by jury.
- Petitioner requested voir dire question about bias toward witnesses who served in or were employed by the military; trial court denied.
- Petitioner was convicted on multiple counts including first degree rape, first degree assault, first degree sexual offense, burglary, and handgun use.
- Court of Special Appeals affirmed; Petitioner sought certiorari to this Court.
- This Court held the trial judge did not abuse discretion; the proposed question was not mandatory under Maryland voir dire law and discretionary to pose.
- Court reaffirmed framework: voir dire aims to uncover cause for disqualification and biases directly related to case; narrowed to relevant, case-specific inquiries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there an abuse of discretion in denying the military-witness bias voir dire? | Washington contends the question was mandatory under Moore/Langley/Bowie. | State maintains the question was not mandatory and within trial court’s discretion. | No abuse of discretion; question not mandatory and properly declined. |
Key Cases Cited
- Langley v. State, 281 Md. 337, 378 A.2d 1338 (1977) (Md. 1977) (bias toward police officer credibility can require probing questions)
- Bowie v. State, 324 Md. 1, 595 A.2d 448 (1991) (Md. 1991) (witness credibility not limited to police witnesses; occupation questions may reveal bias)
- Curtin v. State, 393 Md. 593, 903 A.2d 922 (2006) (Md. 2006) (limits on voir dire and directive that questions must relate to disqualification grounds)
- Dingle v. State, 361 Md. 1, 759 A.2d 819 (2000) (Md. 2000) (trial court has broad discretion; focus on cause for disqualification)
- Moore v. State, 412 Md. 635, 989 A.2d 1150 (2010) (Md. 2010) (witness-occupation questions are mandatory only when relevant to case; broader scope beyond police witnesses)
- Stewart v. State, 399 Md. 146, 923 A.2d 44 (2007) (Md. 2007) (voir dire essential for fair impartial jury; standard for appellate review of discretion)