Admissibility of Computer-Generated Animation: Cases by Jurisdictions

In today's judicial system, computer-generated evidence is already becoming increasingly prevalent, and its use has been addressed in a number of jurisdictions across the United States.
Photo by Bonnie Kittle on Unsplash

When discussing the admissibility of computer-generated animation in jurisdictions, the Federal Rules of Evidence steps to the fore. It applies in United States Federal Courts. Many states in the United States have adopted it with or without variations. To determine the admissibility of certain animation evidence, Rule 401 of the Federal Rules of Evidence provides that the evidence should be tested for relevancy. Rule 402 explains circumstances in which relevant evidence will not be admissible. Rule 702 provides for expert knowledge witnesses. It must be noted that expert witnesses can be given through animation. 

In the United States, certain jurisdictions have added to the progress of admissibility of computer-generated animations through the determination of cases. Jurisdiction means both the authority or power of the court to determine a dispute between parties as well as the territory over which the legal authority of a court extends. We would be considering some jurisdictions and what obtains there concerning the admissibility of computer-generated animation evidence.

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California: People v. Duenas

In the Californian landmark case of People v. Duenas, the issue of the admissibility of computer-generated animation was dealt with. In this case, it was stated that “a computer animation is demonstrative evidence offered to help a jury understand expert testimony or other substantive evidence; a computer simulation, by contrast, is itself substantive evidence.”

As with most cases that deal with the issue of the admissibility of animations, the contrast between animation and simulation came up. The defendant argued that the animation gave the prosecution “ an unjustified air of technical and scientific certainty.” However, the court held that the animation was admissible as it depicts the facts of the case. It can be deduced that in this jurisdiction if the animation successfully explains the fact and does not cause any unjustified advantage, it would be held admissible.

New Jersey: Jones v. Keerfott

Furthermore, the use of computer-generated animation is also adopted in New Jersey. In the case of Jones v. Keerfott Guidance and Navigation Corp, a Mr. Chester William Martin was killed in a crash caused by a loss of power as a result of a defect in the helicopter’s engine. Evidence of this effect was adduced through the use of computer-generated animations.

The defendant argued that the animation was a reconstruction of the facts of the case and not just a guide to help the jury understand the facts of the case. The court explained that “if the animation is introduced to help the jury understand the witness” it would be admissible. The court went further to state that animation was a form of “visualization of the testimony rather than a recreation of the accident.” Because of this, no prejudice was discovered and the animation was deemed admissible. 

Pennsylvania: Commonwealth v. Serge

The Superior court of Pennsylvania was not left out in the determination of the admissibility of computer-generated animation. In the case of Commonwealth v. Serge, the appellant among other things challenged the admission of a computer-generated animation that was used to illustrate expert testimony. The court in the determination of the case explained that “ animation is simply a graphic depiction or illustration of an opinion formed based upon his or her own independent investigation, computation, and analysis.” By “he or she”, the court was referring to the expert.

Animation and simulation should not be confused as the first one sheds light on the evidence of the witness while the other is substantive evidence. In this case, it was held that “ all the requirements for admitting the computer-generated animation into evidence having thus been satisfied, we find the trial court did not abuse its discretion in allowing the jury to view this demonstrative evidence.”

Florida: Pierce v. State

More so, the admissibility of computer-generated animation in court cases has also been approved in Florida. In the case of Pierce v. State, the court held that to adduce an animation illustrating an expert’s opinion, the requirements needed to deliver an expert witness must be established. This method of adducing evidence has also been accepted in jurisdictions such as Connecticut, Alabama, Georgia if certain elements have been proved. On the other hand, some jurisdictions have never dealt with such cases. 

Jurisdictions 2
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Conclusively, the methods of adducing animations as evidence vary from one jurisdiction to another. However, it is an effective method of adducing evidence in court.

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