Coughlin v. Massaquoi (majority)Annotate this Case
The facts of this matter arose out of a fatal accident involving a collision between a motor vehicle and a pedestrian. In this appeal by allowance, the Pennsylvania Supreme Court considered the admissibility of the pedestrian’s postmortem blood alcohol content (“BAC”) in a personal injury action against a motorist and, whether independent corroborating evidence of the pedestrian’s intoxication was required, in addition to expert testimony interpreting the BAC, before the BAC evidence may be admitted. The Court declined to adopt a bright-line rule predicating admissibility on the existence of independent corroborating evidence of intoxication and instead held that the admissibility of BAC evidence was within the trial court’s discretion based upon general rules governing the admissibility of evidence, and the court’s related assessment of whether the evidence establishes the pedestrian’s unfitness to cross the street. Thus, the Court found the trial court properly exercised its discretion in admitting the BAC evidence at issue and affirmed the Superior Court order.