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Opinion testimony on recklessness barred from trial of officer involved in fatal wreck

A state police accident reconstructionist will not be allowed to give his opinion as to whether the actions of a fellow trooper support a vehicular homicide charge, Columbia County Senior Judge Thomas James Jr. ruled Monday, according to a report from PennLive.com.

James, who was specially assigned the case, said that neither the prosecution nor defense may present opinion testimony on the alleged recklessness of Trooper Michael J. Brown, 36.

Brown has been charged with vehicular homicide and vehicle code violations that include passing in a no-passing zone and following too close for allegedly causing a fiery accident on Route 6 in Tioga County on Feb. 11, 2023, that claimed the life of a 47-year-old teacher and mother of three, Christine E. Woodward, of Troy, the news outlet reported.

Brown was in his private vehicle on his way to the Mansfield PSP barracks to begin his 11 p.m. shift when the accident occurred, according to reports.

Brown started to pass the other vehicle after rounding a curve before a passing zone at a dip that prevented him from seeing an oncoming car, officials said, according to PennLive.com.

Though not injured in the crash, Woodward was trapped in her car and died from thermal injuries when both vehicles caught fire, according to court testimony.

Brown admitted that he began to pass a second vehicle while in a no-passing zone, lead investigator Cpl. Jeffrey Vilello testified at the preliminary hearing in September, per PennLive.com.

During two interviews, Brown stated that he did not think he was running late to work and estimated his speed at 45 to 55 mph in the 55 mph zone, though data from the airbag control module in Brown’s vehicle indicated he was traveling about 58 mph five seconds before the crash and approximately 69 mph two seconds before.

He was very emotional during calls to 911 and the Mansfield barracks when reporting that the vehicles were on fire, the investigator said.

The prosecution then called accident reconstructionist Cpl. Gary Beadle to give his analysis of the accident, who, under cross-examination by the defense, said it was his opinion Brown had not acted in a reckless or grossly negligent manner, disagreeing with Vilello’s conclusion the investigation supported Brown being charged, PennLive.com reported.

He testified that in his opinion Brown had not acted recklessly because his speed was not egregious, it had increased gradually and he attempted to take evasive action.

Senior Deputy Attorney General Tracy S. Piatkowski sought the order to prevent a repetition of the surprise testimony.

Beadle’s written report contained 11 conclusions to explain how the crash occurred but none of them mentioned recklessness, Piatkowski wrote in asking the judge to bar the opinion testimony.

James concluded that although Beadle calls himself as an expert in investigative and scientific arenas, he is not an expert on legal matters, and cannot provide a lay opinion regarding recklessness of a accident that he did not witness, according to PennLive.com

Expert testimony is permitted to help jurors understand matters that are beyond the understanding of the average layperson, the judge said, explaining that testimony on Brown’s alleged recklessness is not necessary because jurors are capable of making that determination after hearing the testimony and applying the facts to the definition of the law.

The defense is also precluded from presenting any evidence regarding the prosecution’s decision to charge, with Brown calling it “totally irrelevant” to the issue of whether the trooper committed any crimes, the judge ruled, PennLive.com reported.

Brown is currently suspended without pay, and free on $50,000 bail while awaiting trial in Tioga County.

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