Supreme Court of Maryland

Mitchell v. State

August 14, 2024488 Md. 1

Summary

The Supreme Court of Maryland held that voir dire must address potential disqualifying bias concerning a child witness when the witness's age may affect jurors' credibility assessments and the testimony is important to the case. The trial court abused its discretion by asking only whether jurors had concerns about a child testifying, because that question did not adequately reveal age-based credibility bias and the court should have reformulated the defense request. The court partially abrogated its prior precedent, reversed the intermediate appellate judgment, and ordered a new trial.