Bray v. Bi-State Development Corporation

Rosemary Bray (plaintiff) broke her shoulder, arm, and kneecap falling in a parking garage run by Bi-State Development Corporation (BSDC) (defendant) and sued for personal injury. At trial, BSDC introduced a computer-generated chart showing the garage's lighting levels at the time of the fall, supported by expert testimony that the program produced accurate results and an explanation of the relevant variables. The jury found for BSDC, and Bray appealed, arguing BSDC never laid a proper foundation for the chart before it was admitted.

Whether a party seeking to authenticate a computer-generated simulation must present evidence describing the creation process and demonstrating the simulation's accuracy.