State v. Anderson
A court can permit the introduction of computer anime of a motor-vehicle accident that will help the jury to comprehend the testimony and report of an accident reconstruction expert. The government charged the defendant, who was driving a Milford police department cruiser, with second-degree manslaughter and reckless driving, as a result of the deaths of two individuals in a motor-vehicle accident, and requested court permission to introduce computer animations of the subject accident. The defendant police officer, Jason Anderson, objected that the potential prejudice was greater than the probative value of the evidence. To help the jury to comprehend expert testimony, a computer animation must be fair and accurate and not unduly prejudicial. Scenes 1, 2 and 3 are consistent with an accident reconstruction expert's report and testimony. At trial, the court can provide a limiting instruction to the jury. The court granted the government's motion to introduce evidence of scenes 1, 2 and 3, which illustrate the speed and direction of travel and the manner of collision from above the subject accident. The court denied the government's motion to introduce evidence of scenes 4, 5 and 6, which illustrate the subject accident through the windows of motor vehicles. These computer animations were conjectural and unduly prejudicial, especially scene four, which purports to show a motor vehicle as it rolls over. The court also denied the government's motion to introduce evidence of scene 9, which adds daylight. The addition of sunlight is unduly prejudicial. The court reserved judgment on scenes seven and eight, which purport to add "ghost" vehicles that are traveling at the speed limit. In a separate memorandum, the court granted the government's motion to exclude evidence that the victims were not wearing seatbelts at the time of the motor-vehicle accident. Evidence that the victims were not properly restrained does not constitute an intervening, superceding cause of death and does not relieve the defendant of criminal responsibility.