Danny Trotman v. State of Maryland, 463 Md. 526

Summary

The Maryland Court of Appeals held that a trial court may not summarily excuse prospective jurors because of disabilities. A prospective juror may be excused on disability-related grounds only when no reasonable accommodation is possible and the particular disability would prevent satisfactory jury service at the trial. The court upheld the excusal of four prospective jurors who could not use the staircase leading to the jury room because the trial court found that no alternative courtroom was available.

Holdings

1. A trial court may not summarily excuse prospective jurors with disabilities from jury service solely because of their disabilities.
2. A trial court may excuse a prospective juror for cause on a disability-related ground only if no reasonable accommodation is possible and, at that particular trial, the particular disability would prevent the prospective juror from providing satisfactory jury service.
3. The circuit court did not abuse its discretion in excusing the four prospective jurors who could not use the twenty-five stairs leading to the jury room.

Questions Presented

1. Whether the circuit court violated the Americans with Disabilities Act and Maryland jury-service statutes by excusing four prospective jurors with disabilities for cause because they could not use the stairs leading to the jury room.
2. Whether a trial court may excuse a prospective juror on a disability-related ground without first considering reasonable accommodations.
3. Whether, under the circumstances, the circuit court abused its discretion by finding that no reasonable accommodation was available.

Disposition

affirmed