Johnson v. StateAnnotate this Case
Data from a business record indicating locations and durations of time determined by a GPS device carried by Defendant was admissible without the need for the State to present expert testimony to explain the operation of, and science underlying, GPS devices.
Defendant, an officer with the Maryland Transit Administration (MTA) police, was convicted of assaulting and raping a woman after driving her home following her involvement in a traffic accident with an MTA bus. During trial, the State introduced GPS data from the mobile GPS device Defendant carried as part of his job that matched the itinerary given by the woman in her testimony. On appeal, Defendant argued that the State should have presented expert foundation testimony concerning GPS devices as a prerequisite to the admission of such evidence. The Court of Special Appeals affirmed the convictions. The Court of Appeals affirmed, holding that the jury did not require expert testimony to understand the operation of a GPS device and the data it generated.