Commonwealth, Department of Transportation v. Taylor

JOHNSON, J.:

¶ 1 In this appeal, we determine whether the Commonwealth of Pennsylvania, Department of Transportation (Penn-DOT), may properly refuse to produce accident reports and other records in response to a court order in a criminal prosecution where the materials to be produced are privileged under certain provisions of the Motor Vehicle Code. See 75 Pa.C.S. §§ 3741-3755. The trial court concluded that the privilege did not protect the materials from disclosure in a criminal action because the materials in question are demonstrably relevant to the defendant’s culpability as charged in…