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Keywords

defendantappealtrialtestimonyvoir direjury trialhearsay
defendantappealtrialtestimonyvoir direjury trialhearsay

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Benton v. State, 224 Md.App. 612, 121 A.3d 246

Facts

Joshua Benton was convicted following a jury trial for the murder of Sharod James, which occurred on November 16, 2012, at a gas station in Prince George's County. The State argued that Benton and his co-defendant, Madhi Lawson, killed James because they believed he had murdered their friend, Matheno Nichols, in 2006. Witnesses at the scene described two men standing over a body, and their clothing matched that of Benton and Lawson as seen in surveillance footage. Additionally, a jailhouse informant testified that there was a belief in the community that James had killed Nichols.

Joshua Benton was convicted following a jury trial for the murder of Sharod James, which occurred on November 16, 2012, at a gas station in Prince George's County. The State argued that Benton and his co-defendant, Madhi Lawson, killed James because they believed he had murdered their friend, Matheno Nichols, in 2006. Witnesses at the scene described two men standing over a body, and their clothing matched that of Benton and Lawson as seen in surveillance footage. Additionally, a jailhouse informant testified that there was a belief in the community that James had killed Nichols.

Issue

Did the trial court err in failing to propound Benton's requested voir dire question regarding whether any member of the venire had been charged with or convicted of a serious offense, and did it err in admitting hearsay evidence?

Did the trial court err in failing to propound Benton's requested voir dire question regarding whether any member of the venire had been charged with or convicted of a serious offense, and did it err in admitting hearsay evidence?

Rule

Trial judges are required to pose voir dire questions directed at exposing constitutional and statutory disqualifications when requested by a party. Failure to do so constitutes an abuse of discretion.

Trial judges are required to pose voir dire questions directed at exposing constitutional and statutory disqualifications when requested by a party. Failure to do so constitutes an abuse of discretion.

Analysis

The court found that the trial court's refusal to ask the requested voir dire question about jurors' prior convictions was a reversible error. This question was necessary to determine if any jurors were statutorily disqualified from serving. The court also noted that the informant's testimony was not hearsay as it was not offered to prove the truth of the matter asserted but to show the belief of the informant and others in the community.

The court found that the trial court's refusal to ask the requested voir dire question about jurors' prior convictions was a reversible error. This question was necessary to determine if any jurors were statutorily disqualified from serving. The court also noted that the informant's testimony was not hearsay as it was not offered to prove the truth of the matter asserted but to show the belief of the informant and others in the community.

Conclusion

The Court of Special Appeals reversed Benton's convictions and remanded the case for a new trial, concluding that the trial court's failure to ask the voir dire question constituted reversible error.

The Court of Special Appeals reversed Benton's convictions and remanded the case for a new trial, concluding that the trial court's failure to ask the voir dire question constituted reversible error.

Who won?

Joshua Benton prevailed in the appeal because the court found that the trial court committed reversible error by not asking the requested voir dire question.

Joshua Benton prevailed in the appeal because the court found that the trial court committed reversible error by not asking the requested voir dire question.

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