Willard H. Williams v. State of Maryland, 394 Md. 98

Summary

The Maryland Court of Appeals held that a defendant is entitled to a new trial when a juror fails to disclose information responsive to a voir dire question and the record does not establish whether the nondisclosure was intentional or inadvertent. The court concluded that the trial judge could not deny a new-trial motion based solely on the perceived remoteness of the juror's relationship without conducting further inquiry and making factual findings regarding bias. The court reversed and remanded for a new trial, declining to resolve the defendant's Brady and Maryland discovery-rule claims.

Holdings

1. When a juror fails to disclose information sought by a voir dire question and the record does not reveal whether the nondisclosure was intentional or inadvertent, the defendant is entitled to a new trial.
2. The court did not decide whether the State was required under Brady or Maryland Rule 4-263(g) to disclose information concerning the investigating officer's prior misconduct because reversal on the juror-nondisclosure issue made resolution unnecessary.

Questions Presented

1. Whether a defendant is entitled to a new trial when a juror fails to disclose information specifically sought by a voir dire question and the record contains no finding whether the nondisclosure was intentional or inadvertent.
2. Whether the State's alleged failure to disclose impeachment information concerning a police officer violated Brady v. Maryland or Maryland Rule 4-263(g).

Disposition

reversed_and_remanded