314 A.3d 922
Pa. Super. Ct.2024Background
- Daquan Lamont Thompson was involved in a fatal car crash in Pittsburgh on October 28, 2017, resulting in one death and multiple injuries.
- Thompson initially denied driving but was later charged and tried non-jury for multiple offenses, including homicide by vehicle while DUI.
- Key evidence included event data recorder (EDR) information from both vehicles, which detailed speed, seatbelt use, and crash dynamics.
- Officer Ronald Wolfe, a crash reconstruction expert, extracted and analyzed the EDR data and testified at trial.
- Thompson was convicted and sentenced to 5½ to 11 years and appealed, challenging the admission of EDR evidence as violating his right to confrontation under the U.S. and Pennsylvania Constitutions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of EDR evidence under Confrontation Clause | EDR data is testimonial; no chance to cross-examine device; violates constitutional rights | EDR data is not testimonial; machine-generated data; Officer Wolfe available for cross-exam | EDR evidence is not testimonial; no violation; affirmed |
Key Cases Cited
- Crawford v. Washington, 541 U.S. 36 (defines "testimonial hearsay" for Confrontation Clause)
- Melendez-Diaz v. Massachusetts, 557 U.S. 305 (forensic laboratory reports as testimonial)
- Commonwealth v. Barton-Martin, 5 A.3d 363 (testimony and Confrontation Clause requirements)
- Commonwealth v. Yohe, 79 A.3d 520 (toxicology reports as testimonial in DUI cases)
- Commonwealth v. Brown, 185 A.3d 316 (autopsy reports as testimonial)
- Commonwealth v. Dyarman, 73 A.3d 565 (calibration certificates not testimonial)
- Commonwealth v. Weeden, 304 A.3d 333 (purpose analysis for testimonial statements)