Preclusion of Testimony Describing Lost Surveillance Footage • Best Evidence Rule • Spoliation of Evidence • Materially Exculpatory Versus Potentially Useful Evidence
Commonwealth v. Williams, PICS Case No. 17-0093 (Pa. Super. Jan. 12, 2017) Strassburger, J. (9 pages).
The trial court erred in precluding testimony describing lost surveillance footage, where such evidence was only potentially useful to defendant, rather than being materially exculpatory. Order of the trial court reversed, case remanded.
