Supreme Court of Maryland

Mitchell v. State

August 14, 2024

Summary

The Supreme Court of Maryland held that a trial court must, upon request, inquire into potential juror bias concerning a child-witness when the child’s age could affect credibility judgments and the testimony is important to the case. The court also held that, although counsel’s proposed question was improperly phrased, the trial court abused its discretion by asking only a general question about concerns regarding child testimony rather than reformulating the inquiry to reveal age-based credibility bias. The court partially abrogated prior precedent, reversed the intermediate appellate judgment, and remanded for a new trial.