Supreme Court of Maryland

Smith v. State

August 26, 2022481 Md. 368

Summary

The court held that courtroom bailiffs’ display of thin blue line symbols on their face masks created an unacceptable risk that the jury would consider impermissible pro-law-enforcement factors, violating the defendant’s Sixth Amendment right to a fair trial. It adopted a case-specific inherent-prejudice framework requiring an objection, record-based observability by the jury, and an unacceptable risk of impermissible influence, subject to a possible compelling-governmental-interest justification. The court reversed the intermediate appellate judgment and ordered a new trial.