Commonwealth v. Safka
95 A.3d 304
| Pa. Super. Ct. | 2014Background
- Appellant Ryan Safka was charged with multiple Homicide by Vehicle, Involuntary Manslaughter, Recklessly Endangering Another Person and other traffic offenses.
- Evidence from the vehicle’s Event Data Recorder (EDR) was admitted to establish Safka’s speed prior to the crash in a bench trial.
- Safka objected during trial; the court admitted EDR data but reserved weight pending further evidence about accuracy and reliability.
- The trial court later reopened the evidentiary record sua sponte to hear additional evidence on EDR reliability, after all evidence had been presented.
- The Commonwealth presented reconstruction and EDR-function testimony; Safka presented no further evidence.
- Judgment of sentence was entered; Safka challenged the admissibility and the trial court’s sua sponte reopening on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether EDR speed data violates Frye | Safka argues EDR data is novel science under Frye. | State contends EDR data is not novel and is generally accepted. | EDR speed data is not novel science; Frye not violated. |
| Whether the trial court could reopen the evidentiary record sua sponte | Trial court lacked authority to reopen without party request. | Court acted within discretion to ensure accuracy of admissibility. | Majority: reopening permissible; concurrence: reversible error; judgment affirmed. |
Key Cases Cited
- Grady v. Frito-Lay, Inc., 576 Pa. 546 (Pa. 2003) (Frye test framework for novel scientific evidence)
- Commonwealth v. Foley, 38 A.3d 882 (Pa. Super. 2012) (Frye two-step analysis for novel scientific evidence)
- Commonwealth v. Harrell, 65 A.3d 420 (Pa. Super. 2013) (standard for reviewing admission of expert scientific testimony)
- Commonwealth v. Mathis, 463 A.2d 1167 (Pa. Super. 1983) (trial court discretion to reopen evidentiary record)