State v. Holm, 2017 UT App 148 (August 10, 2017)

Holm was convicted of negligent homicide resulting from a traffic accident. During voir dire, Holm was not allowed to ask follow-up questions of individuals who had indicated they or someone close to them had been involved in a serious car accident.  The court of appeals reversed the conviction, holding that as proposed voir dire questions draw closer to probing potential bias, the court’s discretion in deciding whether to allow the questioning narrows, and when requested voir dire questions go directly to the existence of actual bias, the court’s discretion disappears.