Friday, December 29, 2006

Singfield v. State (Ct. of Special Appeals)

Decided December 29, 2006 -- Opinion by Judge James P. Salmon.

Appellant appealed on three separate grounds his criminal conviction for murder with a handgun, the first such ground being the trial court's refusal of a voir dire question on the issue of juror prejudice or bias on the basis of the specific charge of murder with a handgun.

The Court of Special Appeals held that the trial court had not adequately addressed the issue of charge-specific bias by granting questions related to whether each juror:

1) had been the "victim of a weapon's charge" [sic] or a weapon's crime or had someone in the family who was accused of a weapon's crime; and

2) had any reason whatsoever . . . that would affect his or her ability to render a fair and impartial decision.

The Court of Special Appeals rejected arguments from the State that no charge-specific voir dire question should issue for a murder with a handgun charge in the manner required in prior Maryland decisions for charges involving certain sex offense or controlled dangerous substance charges. The Court of Special Appeals further noted that Appellant faced other lesser included homicide charges involving imperfect self-defense claims, and that the denied voir dire question was germane to those charges as well.

The Court of Special Appeals accordingly reversed the conviction and remanded the case for retrial on that ground, and did not address Appellant's other grounds.

The full opinion is available in WPD and PDF.

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