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Recent Development: Nash V. State: Jury Note Expressing Concern About Motives Behind A Juroror Ury Note Expressing Concern About Motives Behind A Jurororsumption Of Prejudice Requiring Voir Dire Sua Sponte, Nadya Cheatham

University of Baltimore Law Forum

The Court of Appeals of Maryland held that a note from a jury, containing allegations that a juror would change her original voting position if it meant she could go home earlier, did not raise a presumption of prejudice and therefore did not require the trial judge to conduct voir dire sua sponte. Nash v. State, 439 Md. 53, 94 A.3d 23 (2014). Additionally, the court held that the trial judge did not abuse her discretion when she chose to release the jurors and remind them of their duties under oath, rather than directly assuring the impartiality of the jurors. …