Challenges to DUI convictions frequently involve disputes over the legality of traffic stops, the reliability of police testimony, and whether later discovered information undermines a conviction. In a recent Pennsylvania decision, the court addressed whether evidence of an arresting trooper’s alleged misconduct in unrelated cases justified a new trial based on newly discovered evidence. If you are charged with a DUI offense, you should consider speaking with a knowledgeable Pennsylvania DUI defense attorney to evaluate potential defenses and appellate options in light of current case law.
Facts and Procedural History
It is reported that a state trooper initiated a traffic stop after observing the defendant commit lane violations and follow another vehicle too closely. During the stop, the trooper observed signs of impairment, including bloodshot eyes and the odor of burnt marijuana coming from the vehicle. The defendant admitted to having smoked marijuana earlier in the day and consented to field sobriety testing. Based on the trooper’s observations and the results of those tests, the defendant was arrested for suspected driving under the influence and later consented to a blood draw that indicated the presence of THC at a level impairing safe driving.
Allegedly, the defendant filed a motion to suppress the stop, arrest, and blood test results in municipal court, arguing that the trooper lacked a lawful basis for the stop and that the evidence was obtained improperly. The municipal court denied the suppression motion and, following a bench trial, found the defendant guilty of DUI. Prior to sentencing, the defendant sought extraordinary relief in the form of a new trial, asserting that after discovered evidence revealed the arresting trooper had been involved in other unrelated DUI cases where reports conflicted with video evidence, leading to the withdrawal of charges.
It is alleged that the municipal court initially granted the request for a new trial based on this newly discovered information. The prosecution then filed an interlocutory appeal, and the court of common pleas reversed the grant of a new trial and remanded the matter for sentencing. After sentencing, the defendant pursued further appellate review by filing a petition for writ of certiorari, which the trial court denied, prompting an appeal.
Newly Discovered Evidence in DUI Cases
On appeal, the questions of law and whether the lower court misapplied governing legal principles. The court focused its analysis on the established four part test for granting a new trial based on after discovered evidence.
To satisfy that test, an appellant must demonstrate that the evidence could not have been obtained earlier through reasonable diligence, is not cumulative, will not be used solely to impeach a witness, and would likely result in a different verdict if a new trial were granted. The court emphasized that each element must be proven by a preponderance of the evidence and that failure to satisfy any one prong defeats the claim.
The defendant argued that the evidence of the trooper’s alleged pattern of misconduct in other cases went beyond mere impeachment and instead demonstrated unreliability and absence of mistake in the defendant’s own case. The court rejected this argument, explaining that evidence of misconduct in unrelated cases, when offered to show that an officer should not be believed, is classic impeachment evidence. The court further noted that credibility assessments are central to impeachment and do not constitute substantive proof that the stop or arrest in the present case was unlawful.
The record showed that the defendant had the opportunity at the suppression hearing and trial to cross examine the trooper about the timing of the video recording and other aspects of the stop. The court concluded that the newly discovered material did not establish a nexus between the unrelated incidents and the defendant’s case beyond attacking credibility. Because the evidence would be used solely for impeachment purposes, it failed the third prong of the after discovered evidence test. The court therefore found no abuse of discretion and affirmed the order denying a new trial.
Talk to a Dedicated Pennsylvania DUI Defense Attorney
If you are facing DUI charges in Pennsylvania, understanding how courts treat suppression issues, credibility challenges, and after discovered evidence can make a meaningful difference in your case strategy. Attorney Zachary B. Cooper is a dedicated Pennsylvania DUI defense attorney who can advise you of your rights and help you to seek the best outcome available. To discuss your situation and explore your legal options, contact Attorney Cooper at (215) 542-0800 or reach out through the firm’s online contact form for a confidential consultation.