Commonwealth v. David J. Cronin, Jr.

Summary

The court held that a police officer could testify as a lay witness about the basic operation of a Cellebrite extraction system, the extraction steps he personally performed, and the contents of an understandable extraction report. The officer improperly offered expert-level opinions about the system's reliability and safeguards against altering data, and possibly about certain technical concepts, but the errors were nonprejudicial because the other evidence of possession was overwhelming and the trial was before a judge. The conviction was therefore affirmed.