Monday, June 12, 2017

Traffic Citation Ruled Admissible in Federal Court Action by Federal Magistrate Judge

In the Eastern District Federal Court case of Malantonio v. Boyle, 2017 WL 633997 (E.D.Pa. 2017 Hart, M.J.), a federal magistrate judge denied a defendant's motion in limine to preclude the mention of a traffic citation arising out of a motor vehicle accident.

While the court agreed with the defense that such evidence would be inadmissible in a state court action, the federal court found that, under the Federal Rules of Evidence, the citation was admissible. See 42 Pa.C.S.A. Section 6142(a).

In this regard, the court more specifically found that the traffic citation would not be excluded as hearsay evidence and that the probative value of the evidence outweighed any prejudicial effect.  The court also noted that the defendant would have an opportunity at trial to testify regarding the circumstances surrounding his guilty plea to the citation as well as to explain his actions that led to him being given a traffic citation in the first place.

Anyone wishing to review this decision may click this LINK.

Source:  Course Materials from 2017 PAAJ Auto Law Update CLE.

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