Pennsylvania Superior Court Upholds Admission of Google Maps Timeline Data Without Requiring Expert Testimony

Criminal Defense Lawyer Zak T. Goldstein, Esquire

The Pennsylvania Superior Court has decided the case of Commonwealth v. Jones, holding that the Commonwealth need not call an expert witness to introduce Google Maps timeline data recovered from a defendant’s cell phone. The Court held that no expert is required so long as the testifying witness does not offer their own technical opinion and instead simply replays what the app automatically displays. This decision makes it easier for either side to introduce cell phone location data obtained from various Google apps and records.

The Facts of Jones

At around 2:00 a.m. on June 18, 2024, a masked man robbed a Turkey Hill convenience store in Lancaster County. The store clerk later identified the defendant based on his eyes, dreadlocks, and voice after seeing his Facebook profile. The police obtained a search warrant. After obtaining the warrant, the police seized the defendant’s cell phone and tablet. Both devices were synchronized with and linked to his Google account.

A detective accessed the defendant’s Google Maps “Your Timeline” feature, which automatically logs a user’s past movements when enabled. The Timeline showed:

• The defendant leaving home at 1:35 a.m.,

• The defendant arriving at a hotel directly next to the Turkey Hill at 1:47 a.m.,

• The defendant remaining there until 2:01 a.m., which was the time of the robbery, and

• The defendant then traveling to a nearby Sheetz convenience store, where surveillance video confirmed the defendant’s presence.

At trial, the Commonwealth introduced screenshots of the defendant’s Google Maps data through the detective’s testimony. The defendant objected, arguing that an expert witness from Google or a digital forensics specialist was required to explain how the timeline information was generated. The trial court denied the motion, and the jury convicted the defendant of robbery, theft, and simple assault. He received a lengthy state prison sentence.

The Issue on Appeal in the Pennsylvania Superior Court

The defendant argued on appeal that the Google Maps Timeline contained inaccuracies, including suspicious travel distances and impossible driving times, and that only an expert could explain those discrepancies. Therefore, he claimed, allowing the detective to testify as a layperson about the data violated Pennsylvania Rules of Evidence 701 and 702.

The Superior Court’s Holding

The Superior Court affirmed the judgment of sentence, concluding:

Google Maps Timeline data may be introduced through a lay witness when the witness is simply describing the information displayed on the app and is not explaining any underlying technical processes.

The Court emphasized several key points:

1. The detective did not provide technical or scientific testimony. He accessed Google Maps the same way an ordinary user would. He opened the app and clicked “Your Timeline.” He did not testify about how Google calculates GPS coordinates or how the software functions internally.

2. The data was automatically generated by Google, not manually interpreted by police. Because the app itself creates and stores the Timeline, the officer was merely relaying what he saw on the screen, much like reading business records or phone-company logs.

3. Any inaccuracies went to the weight of the evidence, not admissibility. The defendant pointed to anomalies such as a twelve-minute trip to travel 0.2 miles, but the Court held these issues were for the jury to consider, not grounds for exclusion. The detective freely acknowledged the inconsistencies on cross-examination.

4. Lay testimony is proper when interpreting data within common understanding. The Court compared the case to Commonwealth v. Grubbs, where a detective testified to cell-site location data without expert qualification because he merely relayed coordinates already calculated by service providers. In contrast, cases where expert testimony was required, such as interpreting technical IP address data, were distinguishable because they involved complex digital processes. In reality, it is not so clear what the difference is.

This opinion signals that Pennsylvania courts will generally treat Google Maps data as non-technical user data, similar to ordinary phone records, so long as:

• The witness does not attempt to explain how the data is generated,

• The witness only describes the app’s output, and

• The prosecution can authenticate the device and account.

It also underscores that defendants may need their own expert if they wish to challenge the reliability of such location data.

The Takeaway

The Superior Court held that Google Maps GPS Timeline screenshots are admissible through lay testimony, and any questions about their accuracy go to the weight of the evidence, not whether the jury may consider them.

This ruling will likely make it easier for prosecutors to introduce Google-based location evidence in robbery, homicide, and gun cases without needing specialized experts, while placing the burden on the defense to identify and challenge inaccuracies through independent expert analysis when appropriate. It does, however, also make it easier for the defense to introduce this evidence should the evidence be helpful to the defendant. In general, this case follows a trend of courts making it easier for the Commonwealth to introduce electronic evidence without requiring much in the way of safeguards.

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