People v. Duenas

A California jury convicted Enrique Parra Duenas (defendant) of first-degree murder of sheriff’s deputy Michael Hoenig. The trial court imposed the jury’s recommended death sentence. At trial, the prosecution (plaintiff) presented expert testimony from Doctor Carley Ward, an expert in the biomechanics of injury, and her son, Parris Ward. Parris Ward created a four-minute animation to illustrate Carley Ward’s opinions that Hoenig’s killer fired a series of shots from different locations, including a few shots that were fired at close range while Hoenig was on the ground. The animation was a sequence of mostly still images that showed objects and figures from different angles. Color autopsy photos were worked into various parts of the animation. The Wards relied on several sources to create the animation, including police and coroner reports, photographs, precise crime-scene measurements, examinations of Hoenig’s patrol car and bulletproof vest, and consultations with the coroner who performed Hoenig’s autopsy and a blood-spatter expert who analyzed Hoenig’s patrol car. Before playing the animation, Parris Ward testified that although the animation was computer-generated, the shooting did not necessarily happen the way that it appeared in the animation. The trial court also cautioned the jury that the animation was based on a compilation of different expert opinions and was not an exact re-creation of what had actually occurred. Further, the trial court stated that the animation was meant to aid jurors in viewing the prosecution’s version of events and interpretation of the evidence. Duenas appealed from his conviction, arguing in relevant part that the trial court had erred by admitting the animation because it was speculative and lent an unwarranted aura of scientific certainty to the prosecution’s case.