The Court of Appeals of Maryland held that the denial of a defendant’s request to be present at voir dire bench conferences is not harmless error when a prospective juror disclosed information of potential bias and was selected to sit on the jury without input from the defendant. State v. Yancey, 442 Md. 616, 617, 113 A.3d 685, 686 (2015). The court determined that the State did not meet its burden of proving the error was harmless beyond a reasonable doubt.
Stern, Shannon A.
"Recent Development: State v. Yancey: Denial of a Defendant's Request to be Present During a Voir Dire Bench Conference With a Juror Who is Later Selected to Serve is Not a Harmless Error,"
University of Baltimore Law Forum: Vol. 46
, Article 10.
Available at: http://scholarworks.law.ubalt.edu/lf/vol46/iss1/10