Government of the Virgin Islands v. Jackson

47 V.I. 123, 2005 V.I. LEXIS 8
CourtSuperior Court of The Virgin Islands
DecidedJuly 6, 2005
DocketCriminal No. 287/2001
StatusPublished
Cited by1 cases

This text of 47 V.I. 123 (Government of the Virgin Islands v. Jackson) is published on Counsel Stack Legal Research, covering Superior Court of The Virgin Islands primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Government of the Virgin Islands v. Jackson, 47 V.I. 123, 2005 V.I. LEXIS 8 (visuper 2005).

Opinion

ROSS, Judge

MEMORANDUM OPINION

(July 6, 2005)

THIS MATTER came before the Court as a result of Defendant’s motion for a Daubert hearing. The Defendant challenged the formulas used in determining the rate of speed the Defendant was traveling on the date of the incident. Accordingly, on February 22, 2002, a Daubert hearing was initiated on the matter.

Factual Background

On May 3, 2001, while traveling west on Melvin Evans Highway, in the vicinity of the Paradise Housing Community, Defendant was [125]*125involved in an incident where his vehicle struck and killed a pedestrian attempting to cross the highway. The pedestrian was pronounced dead at the scene. Thereafter, Officer Joseph Bess conducted a speed test to determine the rate of speed at which the Defendant was traveling prior to braking. In order to determine the rate of speed, Bess used the following formulas:

(1) Coefficient of Friction (“f’)= Pulling Force (“F”)/Weight of Drag Sled (“W”) (“f=F/W”); and
(2) Speed in Miles per Hour (“S”)=Square Root of the Constant 30 multiplied by the Distance in feet (“D”), multiplied by the Coefficient of Friction (“f’), multiplied by the percentage of breaking (“N”) (“S= V 30(D)(f)(N)”).

Defendant moved for a Daubert hearing challenging the validity of the formulas used to determine the Defendant’s rate of speed, and the Court complied.

Expert testimony was presented on both formulas by David Brill, an accident investigation coordinator and instructor at the University of Florida’s Institute of Police Technology and Management. Brill is also a former homicide investigator for the Florida Highway patrol and a published author in the field of traffic accident investigation and reconstruction. Brill was qualified by this Court as an expert to testify regarding the reliability of the coefficient of friction and speed tests based on his knowledge, skill, experience, professional training and education.

Standard of Review

The admission of scientific or expert evidence is governed by Fed. R. EviD. 702. Accordingly, the Court may exercise broad discretion in excluding or admitting scientific evidence. Kumho Tire Co. v. Carmichael, 526 U.S. 137, 143 L. Ed. 2d 238, 119 S. Ct. 1167 (1999). However, before expert testimony or scientific evidence may be admitted, the Court must act as a gatekeeper and determine what evidence helps the jury to resolve the issues presented. See Government of the Virgin Islands v. Byers, 35 V.I. 240, 941 F. Supp. 513 (D.V.I. 1996); Daubert v. Merrill Dow Pharmaceuticals, 509 U.S. 579, 125 L. Ed. 2d 469, 113 S. Ct. 2786 (1993).

[126]*126Super. Ct. VIRGIN ISLAND REPORTS July 6, 2005 [2]The Supreme Court has established a two-prong test to determine the validity and admissibility of scientific evidence. The scientific evidence must be both relevant and reliable. Relevance satisfies the helpfulness standard as determined by the trial court under the guidance of rule 702, and reliability requires a detailed inquiry into the methodology used to form the expert’s conclusion. This inquiry ensures that the methodology is grounded in good science based on more than mere “subjective belief or unsupported speculation.” Belofsky v. General Electric Co., 980 F. Supp. 818, 821, 37 V.I. 334 (1997). [3,4] In Daubert, the Supreme Court identified five nonexclusive factors to be weighed by the Court when determining scientific Reliability: (1) whether the theory or technique can be tested; (2) whether the methodology is subject to peer review and publication; (3) whether, and how frequent, the methodology leads to erroneous results; (4) the known or potential rate of error; and (5) whether the theory or technique has been generally accepted in the relevant scientific field. Daubert, 509 U.S. at 593. In creating these standards, the Daubert Court required trial courts to consider the above factors in their totality. Daubert, 509 U.S. at 593. No one factor is dispositive. As such, the Court’s inquiry must focus solely on principles and methodology, not on the conclusions generated therefrom. Daubert, 509 U.S. at 595. [5,6] In addition to the five factors set forth in Daubert, the Third Circuit Court of Appeals has appended three more factors to be considered when determining scientific reliability: 1) whether, and how strong, a relationship the technique has to methods which have been established as reliable; 2) whether the expert witness is qualified to testify based on the methodology; and 3) whether, and how often, the method has been put to nonjudicial use. 126

[127]*127Byers, 35 V.I. at 246, 941 F. Supp. at 516. The Government bears the burden of proving by a preponderance of the evidence that the challenged methods meet the standards for admission of scientific evidence. See Belofsky at 822.

Analysis

The formulas used by Officer Bess in the accident reconstruction are derived from or rooted in Newton’s Second Law of Motion. See Transcript Vol. I at 17. Brill testified that the formulas have been subjected to testing, and have also been subjected to peer review and publication through the Association of Automotive Engineering, See Transcript Vol. I at 33. Brill testified as to the wide acceptance of the formulas throughout the field of accident reconstruction. See Transcript Vol. I at 34. The formulas are used by the Association of Engineers, General Motors, Ford and other car manufacturers, NASA, and the V.I. Department of Transportation. See Transcript Vol. I at 37. The formulas are also routinely used in the construction of roads and highways. See Transcript Vol. I at 39. Brill further testified that “[ejach of these formulas is dependent upon the training at which this officer undergoes and how meticulous he is to his duties.” Transcript Vol. I at 35. “The only area that can be subjected to error is the data you submit to them for calculation.” Transcript Vol. I at 36.

Defendant’s objections to the formulas focus on the nature of the error rates in the speed formula. However, these objections cannot be directed at the error rate of the underlying formulas. According to Brill’s testimony, if the calculations are performed correctly, the speed can be determined within a high degree of scientific certainty. Defendant presented no evidence on the contrary to this point. Errors occur if the specific officer investigating the accident incorrectly determines the values for the variables in the equation. Officer Bess used the drag sled method to determine the value for the coefficient of friction (/). The drag sled method is a valid method that is taught at the Institute of Police Technology. See Transcript Vol. I at 28. The potential for error is created only if the investigating officer improperly collects the data. See Transcript Vol. I at 36. The test itself, when performed properly, is both valid and reliable.

Defendant also objected to the value that Officer Bess used for the percentage of braking (TV). Braking efficiency is the amount of weight [128]*128distribution on the axis of the vehicle. See

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47 V.I. 123, 2005 V.I. LEXIS 8, Counsel Stack Legal Research, https://law.counselstack.com/opinion/government-of-the-virgin-islands-v-jackson-visuper-2005.