Michele Evans News headline image: Black-Box Evidence on Trial

Brooklyn Judge Orders Reliability Test for Black-Box Cellphone Mapping

By Michele Evans / NYweeklyRecord.com / Date: 8/12/2026

Category: Criminal Courts / Digital Evidence / Police Technology / Due Process

NEW YORK CITY, NY –

A Brooklyn judge has ordered what the court described as New York’s first reliability hearing for TraX, a cellphone-mapping system prosecutors want to use in a murder case.

The August 3 ruling in People v Quarles puts a growing courtroom problem under a microscope: prosecutors increasingly rely on software-generated maps and location claims, while defendants and juries may have little ability to examine the methods inside the machine.

The defendant is charged with second-degree murder and two counts of second-degree criminal possession of a weapon. The charges are allegations. He is presumed innocent unless proven guilty.

Prosecutors seek to introduce maps created with ZetX TraX software using historical cellphone records. The defense asked the court to bar the evidence or, at minimum, hold a Frye hearing to determine whether the methodology is generally accepted in the relevant scientific community.

Justice Dineen A. Riviezzo did not suppress or exclude the TraX evidence. Instead, the court found that prosecutors had not yet established enough about the system’s reliability to let it reach a jury without further examination.

The court described the proposed use of TraX as novel in New York. It noted that courts in other jurisdictions have reached conflicting conclusions and that the record before it contained little peer-reviewed support for the software’s analytical process.

That distinction matters. Historical cell-site records can show which towers handled a phone’s communications. A software platform can then transform those records into a visual presentation. But a polished map may look more precise than the underlying data permits.

The central question is not whether cellphone records exist. It is whether TraX reliably converts those records into conclusions about location, movement and coverage, and whether its methods are accepted by qualified experts.

A Frye hearing is designed to answer that threshold question before disputed scientific or technical evidence is placed before a jury. The prosecution will have an opportunity to present witnesses and documentation supporting the system. The defense can test those claims through cross-examination and its own evidence.

The ruling reflects a basic due-process principle: software should not become credible merely because it produces a professional-looking graphic.

When an algorithm influences a criminal trial, courts need to know what assumptions it uses, how it handles incomplete data, whether its error rate is known and whether independent researchers can reproduce its results.

Commercial systems can complicate that inquiry. Vendors may treat methods as proprietary. Police and prosecutors may rely on training supplied by the company. Defense lawyers may receive a final map without meaningful access to the process that created it.

That imbalance can turn a demonstrative aid into an authority figure. Jurors may see colored routes, plotted towers and time stamps and assume they represent GPS-level precision even when the source data is less exact.

The court’s order does not decide that TraX is unreliable. It decides that reliability cannot be assumed.

The judge also granted hearings on other disputed evidence. A Mapp hearing will examine the legality of a search and seizure. A Mosley hearing will address non-eyewitness identification evidence. Those rulings similarly preserve questions for testing rather than resolving them in advance.

For New York courts, the TraX hearing could reach beyond one prosecution. If the software is being used elsewhere, judges, prosecutors and defense attorneys will look to the record created in this case.

A transparent hearing can establish what the platform can prove, what it cannot prove and what warnings must accompany any map shown to jurors. It can also reveal whether additional disclosure rules are needed when prosecutors use commercial analytical tools.

Criminal cases should not become technology-free zones. Digital evidence can expose false claims, corroborate witnesses and identify suspects. But technology must be tested with the same rigor demanded of any other evidence that could take away a person’s liberty.

The hearing is now the accountability point. Prosecutors must show the method, not just the picture. The defense must be allowed to challenge the process, not merely the conclusion.

Until that record is built, TraX remains what the court recognized it to be: a disputed tool whose courtroom reliability has not yet been established in New York.

Sources

People v Quarles

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