Wilson v. Donegal Mutual Insurance

*43DEL SOLE, Judge,

dissenting:

I would grant a new trial on the ground that the trial court erred in failing to declare a mistrial after Appellee’s counsel intentionally introduced evidence of Appellant’s refusal to take a polygraph examination upon the request of Donegal Mutual’s attorney.

Although the majority holds that the testimony elicited concerning Appellant’s refusal to take a polygraph was irrelevant,1 nevertheless, it finds that a new trial is not warranted for the reason that there was no reference to the test results. The majority also distinguishes the recent Quigley decision from the instant case on the basis that since Appellant never submitted to a test, no inference as to results was possible, that the refusal to take the test was not mentioned repeatedly, and because Appellant explained his reasons for not submitting to the test, [citation omitted]

I disagree. A trial court is required to grant a mistrial when the prejudicial admission of information may reasonably be said to have deprived a party of a fair and impartial trial. Commonwealth v. Rolison, 473 Pa. 261, 274, 374 A.2d 509 (1977); Commonwealth v. Brinkley, 505 Pa. 442, 452, 480 A.2d 980 (1984). I am convinced that the evidence of Appellant’s refusal to undergo a polygraph examination so tainted the proceedings that he was deprived of a fair and impartial trial, and a new trial is required to correct this error.

In the recent decision by the Pennsylvania Supreme Court, Quigley v. Philadelphia Civil Service Commission, 528 Pa. 195, 596 A.2d 144 (1991), the court cited with *44approval Township of Silver Spring v. Thompson, 90 Pa.Commonwealth Court, 456, 496 A.2d 72 (1985) and Commonwealth v. Johnson, 441 Pa. 237, 272 A.2d 467 (1971), which held that any references, explicit or implied, to the results of lie detector tests are inadmissible for any purpose, [emphasis added].

Silver Spring also reaffirmed the unreliability of lie detector tests, noting that there was no concrete evidence of developments in this field which would make polygraph results any more scientifically reliable than when the court held in Johnson, supra, 441 Pa. at 240, 272 A.2d 467, that references to a lie detector test are not permitted because they raised the impermissible inference that the results carried the weight of scientific evidence in certifying the truth of a statement. See also, Commonwealth v. Gee, 467 Pa. 123, 354 A.2d 875 (1976).

The Quigley decision also narrowed the holding in McMullin Appeal, 41 Pa.Commonwealth Court. 474, 401 A.2d 572 (1979), which held that references to a polygraph examination without mentioning the results of that examination were not prejudicial where examination results were not relied on and the findings were supported by other substantial evidence. Quigley held that references at trial to a polygraph test, and the mere inference that could be drawn from these references, i.e., that the subject had passed the test, was sufficient to taint the proceeding and cause incurable prejudice, even though there was no explicit mention of the results.

The majority, in distinguishing the instant case from Quigley, states that because Mr. Wilson refused to take the exam, “the inference which our Supreme Court found so offensive in Quigley, that the witness had passed the examination could not possibly have been drawn here.” However, it is clear that the fact-finder would equally draw the opposite inference, that Appellant refused to take the exam because he was lying, which would be equally offensive. A references to a witness’ willingness or unwillingness to take a lie detector test raises an inference as to the test result, *45which in turn unavoidably raises the issue of credibility. Johnson, supra., 441 Pa. at 240, 272 A.2d 467. It is the inference of credibility or lack of credibility which is the problem, not whether the witness would have passed or failed the lie detector test.

Nor am I persuaded that Appellant’s explanation for his refusal to take the test reduced the inference that he was lying. In Johnson, supra., 441 Pa. at 242, 272 A.2d 467, cited in, Quigley, supra., curative instructions which charged the jury to limit its considerations strictly to the fact that the test had been administered were considered insufficient to remove the prejudice. If such instructions were insufficient, I can not accept that a mere explanation could have lessened the prejudice. Moreover, Mr. Wilson’s statement that he had refused to take the test because his attorney had advised him not to take it, is an extremely weak excuse in light of his earlier testimony that he had offered to pay for polygraph tests for various municipal officials with whom he had an ongoing dispute. (N.T., May 24, 1990 at 108).

Justice Larsen, who concurred in the finding that the appellant had been deprived of due process by the introduction of the polygraph evidence in the administrative proceeding, stated, “We must be scrupulous in insuring that every person who is accused of wrongdoing and whose liberty and/or substantial property interests are at risk is afforded a fair trial before a fair and impartial tribunal.” Quigley, supra., (Justice Larsen concurring and dissenting) (emphasis added).

I believe that we must be equally scrupulous in the present action. In the context of personal injury actions, the supreme court held in Cook v. Philadelphia Transportation Co., 414 Pa. 154, 199 A.2d 446 (1964), that the defendant was foreclosed from mentioning the name of a bar in the vicinity of an accident on the basis that there was no evidence that any of the participants in the accident had been drinking on the premises, while it was obvious that the plaintiff could have been irreparably prejudiced by testimo*46ny that she came out of a place called the “Crazy Bar”. Mr. Justice Musmanno eloquently stated:

[T]he ‘Crazy Bar’ was wholly alien to the accident, in no way contributed to the happening or an explanation of the accident, and the only possible advantage the defendant could have obtained by filling the jury’s ears with the cry of ‘Crazy Bar,’ would have been an advantage it was not entitled to, but which might well have brought about a mistrial. Id., 414 Pa. at 158, 199 A.2d 446.

See also, Morreale v. Prince, 436 Pa. 51, 258 A.2d 508 (1969), (in which a reference to the Club 30, an “after-hours” bar in Pittsburgh, required reversal of a verdict because it was unduly prejudicial.)

In the present case the intentional reference to Appellant’s refusal to submit to a polygraph gave the defendant/insurance company an advantage to which it was not entitled. It is certainly no less prejudicial to refer to a refusal to submit to a lie-detector test than it is to mention the name of a bar.

Furthermore, the testimony concerning this refusal was not, as the majority holds, “a passive mention” of Wilson’s refusal to take a lie detector test, [citation omitted] On the contrary, it was responsive to a direct question posed by the defendant’s attorney. Furthermore, it is unlike Commonwealth v. Brinkley, 505 Pa. 442, 480 A.2d 980 (1984), and Leonard v. Pennsylvania State Police, 125 Pa.Commonwealth Court 641, 558 A.2d 174 (1989), on which the majority relies, in that testimony concerning lie-detector tests was considered non-prejudicial because the witnesses blurted out emotional and unresponsive answers to questions without mentioning the results of the tests. In these cases the party examining the witness was not attempting to pursue an unfair advantage by calling attention to the witness’ willingness or unwillingness to submit to the exam, whereas, here, as in Quigley, Donegal intentionally elicited this information from Appellant in a narrowly framed question in order to call attention to Appellant’s lack of credibility.

*47Therefore, I would find that Appellant’s testimony concerning his unwillingness to take a lie-detector test had no probative value and was highly prejudicial. On this basis I would grant Appellant a new trial.

. The majority states, "whether or not to admit evidence is within the discretion of the trial court and will not be reversed absent a manifest abuse of discretion” [citation omitted]. I agree with my colleague, Judge Wieand, in Commonwealth v. Wagner, 383 Pa.Super. 128, 556 A.2d 462, 466 (Wieand, J., concurring), that the courts should stop making the misleadingly broad statement that the admissibility of evidence is discretionary. The admissibility of evidence is determined by the rules of evidence, and the better approach is to state that a determination of the relevancy of evidence requires an exercise of discretion and will not be reversed absent an abuse of that discretion.