Molter, J.
A jury convicted Kyle Doroszko of involuntary manslaughter, but the State concedes the trial court violated Indiana Trial Rule 47(D) by denying his counsel the opportunity to voir dire prospective jurors directly. Because that error was not harmless, we must reverse Doroszko’s conviction and remand to the trial court for a new trial.
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Doroszko appeals his conviction on the ground that the trial court violated Trial Rule 47(D) by prohibiting his attorney from questioning the prospective jurors directly. We agree, and because the error was not harmless, we reverse and remand for a new trial.
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As the State acknowledged at oral argument, the parties now agree the trial court ran afoul of Trial Rule 47(D) during voir dire when it prohibited Doroszko’s counsel from questioning prospective jurors directly. That provision states:
The court shall permit the parties or their attorneys to conduct the examination of prospective jurors, and may conduct examination itself. The court’s examination may include questions, if any, submitted in writing by any party or attorney. If the court conducts the examination, it shall permit the parties or their attorneys to supplement the examination by further inquiry . . . .
Ind. Trial Rule 47(D) (emphasis added).1 By directing that the court “shall” permit the parties or their counsel to examine prospective jurors, the rule forecloses any trial court discretion to supplant the parties’ examination with its own. Indiana C.R. Comm’n v. Indianapolis Newspapers, Inc., 716 N.E.2d 943, 947 (Ind. 1999) (discussing “Indiana case law that presumptively treats ‘shall’ as mandatory”).
The rule’s history confirms this interpretation. It previously tracked its federal analogue, directing that the court “may” permit the parties or their attorneys to examine the prospective jurors, or the court could conduct the examination itself. See T.R. 47(D) (1983). But in 1987, we amended the rule to direct instead that trial courts “shall” permit the parties and their attorneys to examine the potential jurors directly. See T.R. 47(D) (1987). We explained the current rule in Logan, emphasizing the word “shall” before explaining that the trial court erred by not permitting the defendant or his attorney “to directly question prospective jurors concerning their views.” Logan, 729 N.E.2d at 133 (emphasis added).
Given the rule’s history, the fact that we squarely addressed this same issue in Logan, and the reality that it is just as important to prosecutors as defense counsel to question prospective jurors directly, it is unsurprising the State now concedes error. But we also understand why the trial court made this error and why the State previously defended it. After directing the trial court to allow parties or their counsel to examine prospective jurors, Trial Rule 47(D) goes on to say a trial court “may conduct examination itself,” so long as it “permit[s] the parties or their attorneys to supplement the examination by further inquiry.” T.R. 47(D). The rule refers to this sort of court-led inquiry as “the examination,” which could be misunderstood to suggest it is instead of, rather than in addition to, a party- or counsel-led inquiry. Id. (emphasis added). That language caused another Court of Appeals panel to mistakenly find no error in the voir dire procedure at issue here in another trial presided over by the same judge in this case. Peppers v. State, 152 N.E.3d 678, 686–87 (Ind. Ct. App. 2020), trans. not sought. We are also aware of a “benchbook” available to our trial court judges which, until recently, mistakenly advised that the procedure used here is proper.
It is therefore worth reiterating the voir dire framework Trial Rule 47(D) establishes. Trial courts must permit parties or their counsel to question prospective jurors directly. Logan, 729 N.E.2d at 133. The trial court may also examine the jurors. T.R. 47(D). As part of its own examination, the court may, but does not have to, include questions the parties submit to the court in writing. If the court elects to examine the prospective jurors, it is within its discretion to decide whether its examination or the parties’ examination will occur first, but whenever the trial court examines the prospective jurors, it must allow the parties an opportunity to supplement the court’s inquiry by posing their own additional questions directly to the prospective jurors.
Importantly, while we reiterate the Trial Rule 47(D) framework we recognized in Logan, we do not recede from any of our precedents. Trial courts retain “broad discretionary power in regulating the form and substance of voir dire.” Logan, 729 N.E.2d at 133. That includes that they “may impose an advance time limitation” on the examination (liberally granting additional time for good cause). T.R. 47(D). And they “may prohibit the parties and their attorneys from examination which is repetitive, argumentative, or otherwise improper.” Id. “Questions which seek to shape a favorable jury by deliberate exposure to the substantive issues in the case,” effectively asking prospective jurors “how they would vote,” remain improper. Davis v. State, 598 N.E.2d 1041, 1047 (Ind. 1992).
Here, the trial court went beyond setting reasonable limits on voir dire. It completely deprived Doroszko of his right to question prospective jurors directly, which the parties appropriately acknowledge ran afoul of Trial Rule 47(D). But not every error leads to a new trial. We only reverse if the error may have made a difference, which we consider next.
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We note the limited nature of our holding. We reverse because the trial court’s voir dire procedure violated Trial Rule 47(D), and an error under Trial Rule 47(D) is not harmless if it deprives a party of an adequate opportunity to exercise peremptory or for-cause challenges to prospective jurors based on a key, disputed aspect of the case. The harmless error analysis may yield a different result in a case where an error is something other than a Trial Rule 47(D) violation; where notwithstanding a Trial Rule 47(D) violation, the trial court’s examination or other procedures ensure an adequate ability for the parties to exercise their peremptory and for-cause challenges; or where the error does not relate to a central, hotly contested aspect of the case, like Doroszko’s self-defense claim here.
The trial court erred by denying Doroszko’s counsel the opportunity to directly examine the prospective jurors contrary to Indiana Trial Rule 47(D). That error was not harmless, so we reverse his conviction and remand for a new trial.
Rush, C.J., and Massa, Slaughter, and Goff, JJ., concur.