Easter v. State
115 A.3d 239
Md. Ct. Spec. App.2015Background
- On June 5, 2011, Easter drove an SUV into the rear of another car at high speed; four occupants died or were fatally injured and one survived with serious injuries. Easter’s BAC tested at .24.
- Easter was convicted by a Prince George’s County jury of multiple offenses, including three counts of manslaughter by vehicle and related DUI and traffic offenses; aggregate sentence 30 years.
- At trial the State introduced (1) a blood-alcohol report produced by a Maryland State Police forensic scientist (Shu) and (2) a crash data report from the SUV’s air bag control module produced by a police crash-data expert (Corporal Carson).
- Easter objected to the blood test results on chain-of-custody grounds (mailing and receiving gaps; missing portion of custody form). The trial court admitted the BAC report after testimony describing receipt, sealed packaging, refrigeration, inspection, and no signs of tampering.
- Easter objected to the air bag control module data as insufficiently shown to be reliable and based on an unreliable retrieval methodology/software; the court qualified Carson as an expert and admitted the module data, finding admissibility a weight issue for the jury.
Issues
| Issue | Plaintiff's Argument (Easter) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Admissibility of blood-alcohol test (chain of custody) | Chain broken: kit mailed, unknown handlers, missing portion of custody form; cannot prove the tested blood is the blood drawn | No requirement to call every handler; circumstantial proof and witnesses who controlled kit negate tampering; gaps go to weight | Court: no abuse of discretion; circumstantial chain (sealed kit, mail to lab, receiving, refrigerated storage, inspection) sufficient for admissibility |
| Admissibility of air bag control module data/expert basis | No showing of reliability of module data or retrieval method/software; expert lacked engineering parameters and used older retrieval software | Expert training/experience and accepted retrieval method among reconstructionists is sufficient; challenges affect weight not admissibility | Court: no abuse of discretion; expert had sufficient basis and the black-box data is generally reliable; admissible, weight for jury |
Key Cases Cited
- Hajireen v. State, 203 Md. App. 537 (Md. Ct. Spec. App.) (trial court evidentiary rulings reviewed for abuse of discretion)
- Best v. State, 79 Md. App. 241 (Md. Ct. Spec. App.) (chain of custody needed to demonstrate integrity of physical evidence)
- Jones v. State, 172 Md. App. 444 (Md. Ct. Spec. App.) (gaps in chain usually affect weight, not admissibility)
- State v. Simms, 420 Md. 705 (Md.) (standard of review for evidentiary rulings)
- Commonwealth v. Zimmermann, 873 N.E.2d 1215 (Mass. App. Ct.) (event data recorder/black-box data admissible and reliable)