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[1996] 4 Web JCLI">

Computer-Generated Displays in the Courtroom: For Better or Worse?

Declan O’Flaherty B.A.

Postgraduate Student
The Queen’s University Belfast
Northern Ireland
< P9580786@Queens-Belfast.ac.uk>

Copyright © 1996 Declan O'Flaherty.
First Published in Web Journal of Current Legal Issues in association with Blackstone Press Ltd.

Summary

Much has been written about computer-generated evidence in the courtroom and most of it has focused on the admissibility of such evidence. However, in this article the intention is to shift the emphasis towards more practical aspects of the topic. Accordingly, a distinction will be drawn between the main types of computer-generated displays in use today. This is followed by a brief analysis of the processes involved in the production of these displays. Next, the benefits and drawbacks of using the technology will be considered. Finally, a number of practical steps are proposed which could be taken to make the use of computer-generated displays more equitable.

Bibliography

Introduction

Picture this scene. In a moment of high drama in a complex case arising out of a road traffic accident, the jury are instructed to don specially designed helmets and gloves. Then, an expert witness takes the participants through a computer-generated simulation of what he believes took place at the accident scene. The expert controls the progression of the simulation, while enabling the jury to gain their own perspectives on such factors as the quality and character of the road, the position and velocity of the vehicles, the existence of any warnings and the prevailing weather conditions (Gore 1993, p 477). In effect, the jury experiences a re-creation of the actual event in fully interactive three-dimensional (3-D) graphics. Does it sound far-fetched? Perhaps not, and indeed in the near future in the United States, at least, the likelihood of such a scenario being played out in courtrooms all over the country is more of a probability than a possibility.

Computer applications in the courtroom are nothing new. Early uses consisted primarily of organisational tools to help lawyers and judges store and retrieve data quickly (see Leith 1991, pp 139- 148). More recently, major advances in technology have meant that computer-generated displays have been unleashed in the courtroom in an attempt to aid jury understanding of complex events and fact patterns. The scenario depicted above is but an extension of that involving the use of Virtual Reality (1) which its proponents believe possesses the potential to alter dramatically the face of litigation (Gore 1993, p 460).

The use of computer-generated displays is almost commonplace in US litigation where they have been widely praised for their ability to aid jury comprehension. They have also been heralded for their inherent power of jury persuasion in an era where jurors are more than comfortable with the idea of receiving and retaining information via television. Furthermore, computer-generated displays offer significant benefits in terms of presentation of evidence. However, lawyers on this side of the Atlantic have been more cautious in their approach to the use of these displays.(2) Indeed, in this instance it may be proper to err on the side of caution because convincing arguments have been made against the use of the technology in the courtroom. One leading commentator has suggested that every advantage of a computer-generated display "carries with it a concomitant potential for abuse or unintentional misuse that could manipulate a juror's impression of a simulated event" (Berkoff 1994, p 849).

Much has been written about computer-generated evidence in the courtroom and most of it has highlighted the admissibility of such evidence.(3) However, I propose to shift the emphasis towards more practical aspects of the topic. Accordingly, in the next section, a distinction is drawn between the main types of computer-generated displays in use today. This is followed by a brief analysis of the processes involved in the production of these displays I will then highlight both the benefits of using the technology and the potential disadvantages. Finally, a number of practical steps are proposed which could be taken to if not eradicate the abuses, at least make the use of computer-generated displays more equitable.

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1. Types of Displays and Production Techniques

It is important at the outset to draw a critical distinction between the three main types of computer- generated displays currently in use. They are computer animations, simulations and the most recent development, Virtual Reality. In this section, a brief account of the processes involved in the production of these displays is also given.

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a. Animation, Simulation or Virtual Reality?

A computer animation is an actual series of computer-generated images or pictures. Each image in the series is altered slightly frame by frame in order to mimic actual movement, and that which is displayed on the screen is the totality of the exhibit. By contrast, a computer simulation involves the input on many sophisticated rules of physics and mathematics which form the parameters within which the facts of the particular scenario operate. The exhibit that is presented to the jury, therefore, involves infinitely more than the simple image displayed on the screen (Berkoff 1994, p 830). The essential difference between a computer simulation and animation is that "the computer simulation, verified by an expert as being scientifically sound and based on scientific knowledge and physical laws, should demonstrate not what 'might' have happened or what 'could' have happened but what actually did happen" (Hoenig 1993, p 5). However, as Muir (1992, p 4) points out the simulation and animation need not be mutually exclusive. They are sometimes contained in one large program. However, the best computer simulation programs do not usually contain the best quality graphics or animation and vice versa.

Virtual Reality (VR) proceeds one step further than computer simulations and animations by breathing real life into them. VR takes its viewers beyond passive observation of computer-generated displays to the next realm of interactive 3-D simulations. As Gore (1993, p 475) puts it, "while a picture may be worth a thousand words, the power of actually experiencing an event inevitably surpasses that of viewing a picture." VR also takes computer-generated displays even further by making its environment suitable for multi-person participation. VR effectively permits events to be relived. Thus, a multi- person VR approach to litigation could permit the entire jury, experts and lawyers to be within the scene and experience the occurrence. To borrow the words of Gore (1993, p 476) again: "VR empowers its participants to surpass their immediate identities and encounter events from diverse viewpoints with very little expenditure of effort and time."

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b. Production of Computer-Generated Displays

The production of a basic computer animation is a five-step process (Muir 1992, p 5). The first step is the collection of any pertinent data including drawings, sketches, police or accident reports, depositions of eye witnesses, photographs etc. The second step is creating a storyboard, sketching out key events and adding words to the still images to describe the motion that is to be animated. The third step is creating the computer models. Here the input data describing the various objects in the animation are actually built on the computer. The fourth step is composing the motion script. Data or the positions of an object with respect to time are put into the computer to control the motions of the object during the animation. The fifth step is rendering. The computer takes all input data (i.e. lighting, texture and composition of the materials that make up the objects) to determine what the object will look like and renders or calculates a still frame containing the image.

Berkoff (1994, p 831) takes the example of a car accident to explain the production of a computer simulation. The first step is inputting the co-ordinates of the objects that were present at the accident scene. The next step involves calculation of the motions of each object that played a significant role in the accident. The testimony of eye-witnesses and accident witnesses are also taken into account. Berkoff (1994, p 831) notes that:

"While the laws of science provide the rules by which the evidence of the specific incident must abide, the computer provides the best fit within these rules for the complex data handed to it."

Once the basic computer animation or simulation has been produced, the final step is to record the product on either videotape or on CD-ROM or Laser Disc format. While a videotape production takes less time and is significantly less expensive, CD-ROM's and Laser Disc technology are becoming increasingly widespread and offer many advantages, not least of which is the storage capacity they offer. For example, one laser-disc side holds 54,000 pictures, charts and graphs or 30 minutes of moving video, offering greater speed, flexibility and clarity than the usual videotape presentation. Entire depositions, treatises and other materials can be stored on a single disc. (Marcotte 1989, p 54)

VR takes 3-D computer displays a stage further by enabling participants to explore an audio-visual representation of the world where objects can be handled and manipulated in real time and real space. A master computer and software, which create the environment and command the movements of the objects within the scene, are required to achieve VR. Sensors, mounted in a helmet and glove worn by the participant, monitor his/her movements and alter the artificially created environment in harmony with the graphic 3-D objects. The effect of this can be quite staggering:

"Used together, these tools allow complete immersion into a computer-created, human dictated world. Objects are touched, their resistance to movement sensed, and the scene altered at will by the participant." (Gore, 1993, p 467)

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2. Advantages of Computer-Generated Displays in Litigation

This section involves a detailed analysis of the perceived benefits of using computer-generated displays in the courtroom. They are that such displays:

(i) aid jury understanding;
(ii) persuade juries of the correctness of the evidence shown in the display; and
(iii)provide important benefits to an advocate in the presentation of his/her arguments before the court.

Each will now be analysed in turn.

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a. Aid to Jury Comprehension

"Communication is at the heart of litigation; everything else is secondary. Evidence is meaningless if it cannot be transmitted effectively to the fact finder, and from the perspective of the litigator, evidence may be valueless if it is not transmitted persuasively." (Lederer 1994, p 1113)

Computer-generated animations, simulations and virtual reality provide an effective means of conveying evidence to a jury, particularly in complex or technical trials. Berkoff (1994, p 845) recognises the difficulties facing those parties presenting evidence in such trials:

"As the complexity of the issues presented to a jury increases, the amount of interest, comprehension, and retention will decrease. For a party presenting such complex issues to a jury, the object is to present them in the most comprehensible, succinct, and attention-getting method possible."

In a recent survey on jury comprehension the American Bar Association found that the trier of fact is often confused, bored, frustrated and/or overwhelmed by technical issues or complex fact patterns (Gore 1993, p 478). It is often the responsibility of an expert witness to explain such issues to a jury and in this context, computer-generated displays provide a wonderful tool. As Muir (1992, p 4) puts it:

"They offer a bridge for the technical community to communicate complex issues to a lay audience."

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b. Tool of Jury Persuasion

It is also evident that visual displays have a greater psychological impact on juries than purely verbal presentations. Surveys have shown that humans are essentially visual learners. We retain 87% of the information which is presented to us visually while we retain only 10% of what we hear (Borelli 1996, p 453). To quote Berkoff (1994, p 846), it is clear that "visual presentation is more effective than verbal communication, and that verbal communication is most effective when coupled with a visual presentation." From a litigator's point of view, the persuasive value of computer-generated displays is undeniable and an invaluable weapon in his arsenal.

A brief look at a number of the cases in which computer-generated displays were utilised demonstrates the powerful and persuasive effect the technology can have on those who view it. The first use of a computer simulation at trial was entitled "Hexane Explosion" and was utilised in Kentucky case in which a gas leak triggered multiple explosions in Louisville (Berkoff 1994, p 846). If a computer simulation had not been used, the jury would have had to digest cumbersome traditional forms of demonstrative evidence needed to make the same points: diagrams of the chemical plant, maps of the city sewer system, eyewitness accounts of the explosion, and expert testimony on gas testimony. Instead, with the use of computer simulations, the jury was ostensibly able to 'see' what happened. Two days after the jury was shown the computer simulations, the defendants settled the case.

In a 1989 Florida personal injury case, computer-generated displays persuaded the jury to award seven million dollars to the plaintiff (Gore 1983, p 473). The jury failed to believe the defendant's version of the facts that the plaintiff lost control of her car; instead, the computer re-enactment indicated that the defendant's vehicle had collided with the rear of the plaintiff's car thereby causing the accident. In the criminal case of People v McHugh (476 NYS 2d 721 (Sup Ct 1984)), the defence used a computer-generated display to show that the prosecutor's version of events could not possibly have happened (Bardelli 1994, p 1358). In that case, a computer simulation of a car accident revealed the accident's unavoidability due to an uncovered manhole on the road and thus, persuaded the jury to auit the man on trial for manslaughter and drunk driving.

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c. Presentation of Arguments

The use of laser-discs and CD-ROM's for storage allows computer-generated graphics, animations and simulations to be seamlessly integrated into the overall presentation with no interference in the trial process (Walsh 1995, p 29). Put graphically, 10 foot tall stacks of paper and evidence can easily be reduced to 2 or 3 pocket-sized CD-ROM's. One of the most famous cases involving the use of computer-generated evidence was that arising out of the Delta 191 crash at Dallas/Fort Worth Airport in 1985.(4) The crash led to a fierce legal battle between the airline and the US government. Government lawyers in the case were among the first to adapt laser-disc technology for courtroom use. One of the government's lawyers stated the advantage of using the technology to be:

"You don't have to rummage through 30 boxes looking for documents... [Laser discs] allow you to effectively integrate video and documentary evidence." (Marcotte 1989, p 54)

Furthermore, by swiping barcodes, counsel has the ability to instantly retrieve an exhibit. As Kissane- Gaisford (1995, p 473) has written:

"During an oral presentation, the speaker can gracefully intersperse oration with the graphical presentation of evidence, simply by scanning the bar-code mid-sentence. This technique can be used to display the evidence nearly instantaneously, timed to correspond with the end of the talented orator's point for maximum impact."

Once the evidence is displayed, computers can also provide tremendous presentation advantages such as stop-action, varied perspectives and slow-motion. It is also possible to enlarge, highlight, duplicate or compare evidence. This flexibility of computer-generated displays adds greatly to its explanatory power:

"Not only can it go places that are physically impossible to get to in other ways, but once an accident or an event is animated or stored in the computer, the viewpoint can be easily moved to another vantage point, whether it be that of a witness, the pilot of a plane or simply one that gives the viewer a better understanding of what happened." (Muir 1992, p 5)

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3. Potential for Misuse

There is no doubt that computer-generated displays are a powerful tool of persuasion in the armoury of any technologically adept litigator who is prepared to use them. Nevertheless, some commentators have expressed considerable unease about the use of such technology in the courtroom. The consequences of misuse of computer-generated displays cannot be underestimated particularly in the context of a criminal trial where as one writer has noted:

"Rather than an award or loss of money judgement, the defendant in a criminal prosecution is subject to a loss of liberty" (Bardelli 1994, p 1358)

These are not the rantings of Luddite technophobes who prefer the quill-pen to the light-pen but rather represent measured and coherent criticisms of the technology and its use in modern litigation. As such they merit serious consideration and in this section I hope to explore some of those criticisms.

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a. 'Seeing is Believing...'

Critics argue that the persuasive power of computer-generated displays is also their greatest disadvantage. Computer-generated displays invariably leave a strong impression on jurors. Indeed, they tend to mesmerise factseekers and relax their natural critical natures (Jenkins 1976, p 600). The tendency on the part of the jury is to think 'I saw it on TV, therefore it must be true'. Such a conclusion may of course be far from the truth and essentially removes from the jury their fact-finding function:

"The fear is that the highly communicative nature of computer graphics and the myth of the infallible computer will take the decision out of the jury's hands. The old adage 'seeing is believing' may gain extra force in this setting" (Borelli 1996, p 455).

The US case of People v Mitchell (Cal App First Dist Div 2, Marin County Superior Court No. SC-12462-A (1994)) provides an apt illustration of the dangers of adopting such a view. In that case, the defendant, James Mitchell, was accused of the murder of his brother, Artie Mitchell. The defendant claimed he acted in self-defence. The prosecution used computer animation to show that because of Artie's location behind a wall, James could not have seen any threatening gestures made by Artie. Following objections by defence counsel, the judge ordered that the human-like figure representing Artie be replaced by a geometric shape to avoid the risk that the jury might assume as proven fact the position of Artie's hands in the animation. The case highlights the point that computer animations do not always present factual information, rather as Ellenbogen (1993, p 1120) has remarked:

"[They] are simply artfully planned and staged presentations promoting one party's unproven theory."

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b. Prejudicial Effects of Not Using The Technology

The persuasive influence of computer-generated displays on jurors is compounded when an opposing party does not use the technology at trial (Selbak 1994, p 361). A party opting to present a traditional case will often be prejudiced by the use of computer-generated evidence by the other side. The available statistics would seem to support such a view. By 1992, it was estimated that computer- generated displays had been used in 858 cases in the US where litigation took place between major companies. In these, all except 15 settled out of court and in all the 15 cases which went to trial, the side using computer-generated displays was successful (McKeone 1992, p 6).

It would appear that cost is the main reason parties forego the use of computer-generated displays. Such displays can prove to be very expensive indeed. For example, the exhibits in the Delta Airlines case cost the US government between $100,000 and $150,000 to produce. The cost might have been two or three times that figure adding in time and travel of outside experts (Marcotte 1989, p 56). Clearly, such exorbitant costs would be far beyond the resources of the average litigator. The high cost particularly favours prosecutors in criminal cases who will have the state's resources at their disposal against usually less wealthy clients. A related concern alluded to by Selbak (1994, p 361) is that litigants with limited budgets may feel compelled to settle rather than seek a trial on the merits when facing opponents who are able to afford animated graphics.

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c. Potential For Tampering With The Evidence

There is a great deal of scope for tampering with the evidence in computer-generated displays. This possibility was recognised in the dissenting judgement of Justice Van Graafeiland in the US case of Perma Research & Development v Singer (542 F 2d 111 (2d Cir) cert denied, 429 US 987 (1974)). The learned judge stated that although a computer has tremendous potential for generating more meaningful evidence, "it presents a real danger of being the vehicle for introducing erroneous, misleading or unreliable evidence." While computer-generated displays offer apparent advantages in jury presentation such as varying perspectives, slow-motion and stop-action, such facilities can also be used to manipulate the events being shown. As Marcotte (1989, p 56) explains:

"Just as a writer uses punctuation, the selective use of a zoom, close-up and fadeout can accent different points. A constantly moving object can appear to change speed or direction by merely changing the point where it is viewed. While the animation may be technically correct, it can be misleading. The medium shapes the message."

The infamous Rodney King trial provides an analogous illustration of the manipulative use of stop- action in a video-tape. The focal piece of evidence in the case was a video-tape showing the police officers involved beating Rodney King. The defendants lawyers were able to use stop-motion very effectively "to de-emphasise the brutality of the event, slowing real time to a snail's pace and demonstrating the supposedly calculated safety precautions taken by the officers" (Berkoff 1994, p 851).

Even where there is no deliberate attempt to tamper with the evidence, computer-generated displays can be unintentionally misleading. Computer animations in particular rely a great deal upon data collection, human judgement and speculation at each step of the animation process. Since a computer is no better than the human using it, and no human is perfect, it follows that computer-generated displays are also prone to error. This is known at the 'Garbage In, Garbage Out' (GIGO) principle. Hoenig (1994, p 6) points out the danger posed by such human fallibility:

"If an expert plugs 'garbage' into the computer, i.e. date, information or principles that are false, erroneous or misleading, the computer-generated result constitutes 'garbage' unworthy of going to the jury. When the GIGO principle is violated, the jury is not being given scientific evidence that is correct and, therefore, it obviously is not helpful in the search for the truth."

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Conclusion: Some Specific Suggestions

The foregoing discussion has shown that computer-generated displays are a powerful tool for the presentation and explanation of arguments at a trial. However, powerful objections to the use of the technology threaten to outweigh its probative value. In order to avoid this undesirable development, steps need to be taken to eradicate the abuses and ensure the continued growth and development of the use of computer-generated displays in the courtroom. Several commentators have focused on the need to formulate a stringent set of criteria through which computer-generated displays must pass before being admitted in evidence (see e.g. Ellenbogen, 1993, pp 1102-1119; Bardelli 1994, pp 1360-1376). However, rather than re-treading this path, I propose to highlight more practical steps which can be taken by both judge and advocate to avoid misuse of the technology. Firstly, counsel must be vigilant to the ever-present danger of misuse. That means advance preparation, diligent discovery and analysis of the underlying data behind any animated simulations or graphics. During the trial itself, vigorous cross-examination of the expert witness testifying alongside the evidence is necessary to ensure that the display is what it purports to be. As one writer remarked: "They [Counsel] must look upon computer simulations as tools, but tools that require extremely fine tuning." (Berkoff 1994, p 853).

Judges also have an important role to play in avoiding juror complacency about the accuracy of what they are presented with in evidence. Borelli (1996, p 458) points out that the trial judge has almost unlimited discretion especially in summation, to disallow displays that might be so 'realistic' or emotion-provoking as to unfairly prejudice one side. However, it is arguable that this may not be sufficient. Since juries are strongly affected by visual evidence, the prejudicial effect of an improper viewpoint shown live in the courtroom cannot be undone. In these instances, a limiting instruction by the judge, instructing the jury to disregard the highly-prejudicial image would be largely ineffective (Selbak 1994, p 365). A better approach would be for judges to forewarn jurors of the potentially biased nature of the computer evidence before it is shown in court. The cry in this instance would seem to be: 'forewarned is forearmed.'

The issue of prejudicial cost remains. This is likely to be less of a problem in the future as technological advances and increased demand are already resulting in lower costs.(5) In the meantime, steps should be taken to ensure that if one side utilising computer-generated displays, the opposing side should also have access to such a resource. McKeone (1994, p 6) suggests that legal aid should be granted to facilitate this where necessary. Such an approach has found favour among some in the US where for example, the court in US v Stifel (11 433 F 2d 431 (6th Cir 1970), cert denied, 401 US 944 (1971)) stated that

"if the government sees fit to use this time consuming, expensive means of fact-finding, it must allow time for a defendant to make a similar tests, and in the instance of an indigent defendant, a means to provide for payment of same."

Granting legal aid in these circumstances would help to ensure a more equitable playing field as far as computer-generated displays are concerned.

As a tool, computer-generated displays have revolutionised much of today's litigation in complex trials. The development of virtual reality and decreasing costs of the technology means that this trend is likely to continue. However, all those concerned with a trial involving the use of computer-generated displays need to be aware of the potential for misuse associated with the technology and proceed accordingly. The steps outlined above, if implemented, may not eliminate the potential for misuse, but they will certainly help to alleviate the problem to a large extent. Justice and fairness cannot be sacrificed in the pursuit of gains in efficiency. If this happens, "the result could well be 'verdict by cartoon' instead of verdict according to scientific truths" (Hoenig 1993, p 5).

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Bibliography

Bainbridge, D (1996) An Introduction to Computer Law, 3rd ed (London: Pitman Publishing).

Bardelli, E J (1994) "The Use of Computer Simulations in Criminal Prosecutions" 40 Wayne Law Review 1356.

Berkoff, A T (1994) "Computer Simulations in Litigation: Are Television Generation Jurors Being Misled?" 77 Marquette Law Review 829.

Borelli, M (1996) "The Computer as Advocate: An Approach to Computer-Generated Displays in the Courtroom" 71 Indiana Law Journal 439.

Ellenbogen, M A (1993) "Lights, Camera, Action: Computer-Animated Evidence gets its Day in Court" 34 Boston College Law Review 1087.

Fennell, C (1995) "Admission of Proof of Computer-Generated Evidence" 89 Law Society of Ireland Gazette 316.

Gore, R A (1993) "Reality of Virtual Reality? The Use of Interactive, Three-Dimensional Computer Simulations at Trial" 19 Rutgers Computer & Technology Law Journal 459.

Hoenig, M (1993) "Computer Simulations and Other Weapons" New York Law Journal 3.

Horten, M (1994) "Graphic Evidence" Solicitors Journal 1289.

Jenkins, M M (1976) "Computer-Generated Evidence Specially Prepared for Use at Trial" 52 Chicago-Kent Law Review 600.

Kissane-Gaisford, J D (1995) " The Case for Disc-Based Litigation: Technology and the Cyber Courtroom" 8 Harvard Journal of Law and Technology 4716.

Lederer, F I (1994) "Symposium: Changing Litigation with Science and Technology: Technology comes to the Courtroom, and...." 43 Emory Law Journal 1095.

Leith, P (1991) The Computerised Lawyer (London: Springer Verlag).

McKeone, M (1992) "Making or breaking the case: computers in court" Law Society Gazette 29.

Marcotte, P (1989) "Animated Evidence: Delta 191 crash re-created through computer simulations at trial" ABA Journal, December, 52.

Muir, D (1992) "Computer Graphics - Debunking the Myths" Michigan Lawyers Weekly, 30 March, p S3B (Supplement).

Ormerod, D (1995) "Proposals for the Admissibility of Computer-Generated Evidence" 6 Computers and Law 22.

Selbak, J (1994) "Digital Litigation: The Prejudicial Effects of Computer-Generated Animation in the Courtroom" 9 High Technology Law Journal 337.

Walsh, A (1995) "Demonstrative Evidence: 'A Picture Paints a Thousand Words'" 6 Computers and Law 28.

Footnotes

(1) "The term 'virtual' describes a reality that is not a conventional, genuine reality but rather something that exists in contrast to reality, yet operates as if it were actual reality" (Gore 1993, p 460). Back to text.

(2) It has been reported that the first instance of computer-generated graphics being used in a British court took place at Oxford Crown Court in September 1994: R v Wharton (Horten 1994, p 1289) The use of the technology had already been well-established in US litigation by that time. Back to text.

(3) For example, see Bainbridge 1996, ch.28, pp 270-276; Ormerod 1995, pp 22-24. For an Irish perspective on the subject, see Fennell 1995, pp 316-320. Back to text.

(4) In Re Air Crash at Dallas/Fort Worth Airport on Aug. 2, 1985, 720 F Supp 1258 (ND Tex 1989), aff'd, 919 F2d 1079 (5th Cir 1991), cert denied sub nom Connors v United States, 112 S Ct 276 (1991). Back to text.

(5) "What might have cost $1million five years ago would cost $250,000 today" (Marcotte 1989, p 56). Moreover, by purchasing a program such as AutoDesk 3D Studio relatively cheaply, many law firms can do the work in-house and save even more money (Selbak 1994, p 342). Back to text.