Wednesday, December 4, 2013

Commonwealth v. Serge case brief

Commonwealth v. Serge case brief summary
586 Pa. 671, cert denied, 127 S. Ct. 275 (2006)

Defendant was sentenced to life imprisonment following his conviction for first-degree murder,18 Pa. Cons. Stat. § 2502(a), by a county court. The Pennsylvania Court of Common Pleas affirmed the judgment. Defendant appealed the judgment.

Defendant argued on appeal that the trial court erred in admitting a computer-generated animation (CGA) illustrating the Commonwealth's theory of the homicide into evidence. The CGA demonstrated the Commonwealth's argument that defendant tampered with the crime scene to stage a self-defense setting by showing the position of the victim and defendant, and the sequence, path, trajectory, and impact sites of bullets.


  • The state supreme court held that a CGA was potentially admissible as demonstrative evidence, as long as the animation was properly authenticated, it was relevant, and its probative value outweighed the danger of unfair prejudice or confusion, as required by Pa. R. Evid. 401, 402, 403, and 901. 
  • The state supreme court held that the Commonwealth satisfied all of the foundational requirements for admitting the CGA as demonstrative evidence. 
  • Furthermore, the CGA was relevant evidence that enabled the Commonwealth experts to illustrate their opinions and educate the jury on the forensic and physical data. 
  • The alleged prejudicial effect of the CGA did not outweigh its relevance. 
  • Therefore, the appellate court held that the admission of this evidence was proper.

The judgment was affirmed.

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