City of Brook Park v. RodojevAnnotate this Case
The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction for driving his vehicle fifteen miles per hour over the posted speed limit, holding that the results of a speed-measuring device using either radar or laser technology are admissible in court without expert testimony establishing, or the court taking judicial notice of, the reliability of the scientific principles underlying that technology.
During Defendant's bench trial, the trial court admitted into evidence and considered the results of the laser speed-detection device that was used in calculating Defendant's excessive speed without establishing the reliability of the scientific principles underlying the device's technology. The trial court convicted Defendant without specifically taking judicial notice of the device's reliability. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the results of a radar speed-measuring device may be admitted into evidence without expert testimony establishing the reliability of the scientific principles underlying the technology or the court taking judicial notice of the scientific principles underlying that technology; and (2) the fact-finder is required to determine whether the evidence concerning the accuracy of the particular speed-measuring device and the qualifications of the person who used it are sufficient to support a conviction based on the device's results.