FLORIDA FORENSIC ENGINEERING, INC.

6708 Benjamin Road, Suite 500, Tampa, FL• 813-868-FFEI (3334)

Toll Free: 800-966-1946

www.FlaForEng.com

Pedestrian Vehicle Accident Reconstruction

DATE: 02/02/2022 FFEI File # 5792

FOR: Michael R. Hunt

Assistant State Attorney
Eighteenth Judicial Circuit of Florida
Brevard and Seminole Counties

Case: State v. Norris

21-55302 CF

DOI: 6/20/2021 Time of Incident: ~2:20 am

Location: Industry Road ~120 ft north of State Road 528 overpass

PREPARED BY: Srinivas Kadiyala, Ph.D., ACTAR & Elliot L. Stem, Ph.D., P.E.

NOTE: This is a preliminary report. The report contained herein represents preliminary
.findings and opinions to a reasonable degree of engineering probability based on facts
available and analysis performed at the time ofpublication. The right is reserved to continue
the analysis and amend or modify the opinions as new information and data becomes
available through the discovery process.

I. BACKGROUND:

On January 5, 2022, Mr. Michael R. Hunt and Mr. Bill Respess requested that Florida Forensic
Engineering, Inc. perform an accident reconstruction for a collision that occurred on 6/20/2021 at
~2:20 am involving a 2009 Chevrolet Impala driven by Ms. Suzanne Paige Norris. The Chevrolet
Impala was traveling north on Industry Rd approximately 120 ft past State Road 528 overpass
when it struck a pedestrian, Ms. Passion D. Lucas.

Inspections: (Jan 28, 2022)

1. 2009 Chevrolet Impala VIN 2G 1WS57M9912693
2. Scene (daytime and nighttime)

Information considered relevant to traffic accident reconstruction include the following:

1. Traffic Homicide package and report
 2. Traffic homicide photos including scene, vehicle, autopsy photos and evidence collected.
3. Sworn Interview Michael Baker
4. Sworn Interview Gary Horton
5. Scene mapping with FARO scans including geometric proportions & measurements of
evidence markers
6. Body Cam footage
7. SDM image of2009 Chevrolet Impala

II. CRASH INFORMATION & DESCRIPTION:

The 2009 Chevrolet Impala driven by Ms. Suzanne Norris was travelling north on Industry
Road, Cocoa, FL approximately 120 ft north of the State Road 528 overpass when it struck
pedestrian Ms. Passion D. Lucas (slides 2,3,4). In the area of the collision, northbound Industry
Road is two-lanes that narrows down to a single lane with a tum lane to the left. The area of
collision was in a designated work zone. The posted speed limit in that area is 45 mph located
approximately 300 ft south of the area of collision. There were no sidewalks, cross walks,
pedestrian signage, or lights in the vicinity of the accident location. The traffic homicide
investigative report is consistent with photographic documentation of the scene evidence.

Ms. Suzanne Norris stated that she was driving home on Industry Rd and without warning
her windshield exploded. She indicated that she continued to drive. After several hundred yards
she turned around and came back. Upon arriving back at the scene, she saw a person lying in the
middle of the roadway.

III. CRASH DYNAMICS ANALYSIS SUMMARY AND CONCLUSION:

Slides 3, 4 show the 1st piece of evidence as a shoe in the middle of the northbound lanes
of Industry Road. All other debris found was further north and in positions shown. The final
position of Ms. Lucas was 78 feet from the 1st piece of evidence.

Slide 6 depicts that the scene changed during the course of the investigation. Still from the
BodyCam footage from RBSl (earliest officer to arrive on the scene) show no evidence
corresponding to Markers 18, 20, 21 depicted in scene photographs taken later.

Slides 7,8 depict the property damage to the Chevrolet Impala's front, windshield,
passenger side of the hood and the passenger side A-pillar. The damage is consistent with the
vehicle striking the pedestrian on the front passenger side, the pedestrian's body wrapping over the
hood along the passenger side of the Impala and striking the windshield prior to being thrown
forward with a minimal passenger side bias. Contact damage is visible to front passenger side of
hood, windshield, and passenger side A-pillar. The front passenger side headlight assembly is
broken. Examination of the bulbs indicate hot shock (i.e., the headlamps were lit at time of
collision).

The lower body of the pedestrian contacted the bumper and the hood, and the upper body
contacted the windshield and the passenger side A-Pillar. The location of the upper body contact
on the windshield is in-line with the initial impact imprint on the front passenger side headlamp

2
and hood. This contact indicates that as the pedestrian's body rides up the hood into the windshield
there is no lateral motion consistent with the pedestrian moving across the car front.

Slide 9 depicts the results of the pedestrian throw analysis after the collision. The speed
of the Chevrolet Impala at impact that was computed is consistent with the documented physical
evidence. As shown in Slide 3 and 4, the first evidence of collision was the shoe on the lane
divider of the two northbound lanes and the pedestrian is approximately 78 ft north from there.
Assuming the shoe to be near the area of impact, pedestrian throw calculations indicate that the
Impala was travelling between 36 mph to 41 mph (average of 38.5 mph) at impact. There is no
evidence of preimpact braking.

The Impala with a weight of 3793 lbs. incurred a fl V of 1.17 mph because of collision with
a 140 lb. pedestrian. The resultant impact force on the pedestrian was 2560 lbs.

There is no indication that the pedestrian went over the passenger side of the vehicle.

The imaging of the Chevrolet Impala SDM revealed that neither a deployment event nor a
non-deployment event was stored in the SOM as a result of the subject collision.

The average recognition distance for drivers in moving vehicles to recognize objects along
the roadside varies based upon a number of factors including ambient lighting, pedestrian
movement, headlight type, pattern, object size, position left versus right and the shade of the object.

Slides 5, 10-13 show that the area has no street lighting. The measured vertical light levels
in the area of the collision were 0.07 lux to 0.24 lux and the measured horizontal light levels was
0.02 lux average. i.e., the area requires artificial illumination to illuminate terrestrial objects.
Pedestrian visibility and recognition in the area of the collision is restricted as can be seen in Slide
11. The average recognition distance on an unlit road with vehicle headlights as calculated and
measured was 155 ft (range between 100 ft to 200 ft).

Slides 14-15 show the calculated average PRT to be 1.9 sec with 85 percentile response in
2.6 sec. A vehicle travelling at an average speed of 38.5 mph (56.6 ft/s) will have travelled 107.5
ft (147 ft for the 85-percentile response) prior to initiating an avoidance maneuver such as braking
or a braking and steer. The average recognition distance on an unlit road is 155ft for a pedestrian
in dark clothing. Therefore, the initiation of an avoidance maneuver would be close to impact or
after the impact has occurred on the passenger's side and is consistent with published values of
response distances of objects entering from passenger's side into the headlight illuminated path
from on-road experiments 1• The evidence indicates in the subject dark unlit roadway this accident
is unavoidable.

Summary of Analysis & Conclusions:

• Location of incident is characterized by roadway construction and an absence of sidewalks,
crosswalks, and street lighting. (Slides 2,3, 5, JO, 11)
• Location of the collision between the Impala and the pedestrian is in the vehicular way
(northbound lanes oflndustry Rd).

1 SAE 2013-01-0787 Determining When an Object Enters the Headlight Beam Pattern of a Vehicle

3
 • Property damage & pedestrian throw calculations is consistent with Chevrolet Impala
travelling 36 mph - 41 mph at impact. (Average 38 mph) (slide 9).
• Physical evidence pattern and pedestrian throw (slides 3, 4) is consistent with the Impala
braking post collision.
• There is no evidence of pre-collision braking by the Impala.
• Property damage does not indicate pedestrian was moving laterally at appreciable speed
across the front of Chevrolet Impala at impact. (Slides 7,8)
• The measured light levels in the area of collision:
• Vertical - 0.07 to 0.24 lux average
• Horizontal - 0.02 lux average
• Artificial illumination is required to illuminate terrestrial objects in area of collision. (Slides
5, JO)
• Average recognition distance in measured lighting conditions is 155 ft (range 100 - 200
ft). (Slides 11-13)
• Average PRT = ~1.9 sec; 85 %ile stopping distance is ~268 ft, 85 %ile stop and steer
distance is ~231 ft. (slides 14, 15)
• This accident is unavoidable by the Impala driver. The pedestrian created the hazard by
walking in the vehicular way.

The analysis results and conclusions herein represent the preliminary engineering analysis based
on the information indicated and available at this time. The methods employed and results herein
are provided to a reasonable degree of engineering and accident reconstruction certainty.

Reviewed by:
02/02/2022
Srinivas Kadiyala, Ph.D., ACT AR Elliot L. Stem, Ph.D., P.E. Date
Principle Forensic Engineer Principle Forensic Engineer

4
rl
 Analysis
Location of incident is characterized by roadway construction and an
absence of sidewalks, crosswalks and street lighting. (slides 2, 5, 10, 11)
Property damage & pedestrian throw calculations is consistent with
Chevrolet Impala travelling 36 mph - 41 mph at impact. (average 38
mph) (slide 9).
. . . . . . p es Sc
Physical evidence pattern and pedestrian throw (slides 3, 4) 1s consistent !' - - ~
with the Impala braking post collision .
There is no evidence of pre-collision braking by the Impala.
Property damage does not indicate pedestrian was moving laterally at
appreciable speed across the front of Chevrolet Impala at impact.
(slides 7,8)
The measured light levels in the area of collision :
Vertical - 0.07 to 0.24 lux average
Horizontal - 0.02 lux average
Artificial illumination is required to illuminate terrestrial objects in area 4::,
of collision. (Slides 5, 10)
Average recognition distance in measured lighting conditions is 155 ft
(range 100 - 200 ft). (Slides 11-13)
1 +-
Average PRT = ~1,9 sec; 85 %ile stopping distance is ~268 ft, 85 %ile
stop and steer distance is ~231 ft. (slides 14, 15)
This accident is unavoidable by the Impala driver. The pedestrian
created the hazard by walking in the vehicular way.

2
 M

ro
.....
ro
-0
C
ro
u
V)
L..
QJ
V)
ro
Cl
rt')

E
0
L..
'+-
QJ
u
C
QJ
-0
>
QJ
'+-
0
.....
::J
0
_.ro
 The area of the incident is not well illuminated (photos taken June 20, 2021)

Without flash With flash

.,
 Evidence Markers 18, 20 & 21 are not related to the subject collision

Scene photograph AMS 2706.jpg Still from Bodycam footage RBSl

(Note : absence of marking consistent with markers 18, 20 & 21)

6
Property Damage is not consistent with pedestrian having significant lateral motion from passenger side to drivers' side at impact
(i.e., pedestrian was not moving across car front laterally at impact)

Chevy Impala collision damage is not consistent with an avoidance maneuver of steer

7
oc
 Calculation of Impala speed at impact
(range ~36 mph - ~41 mph)

Brrl~rttn
"' "'
vcRWare
NOTATIOt4 COOR01~~TES W-<ITS & VARlABLES
c"°'dlr1ace pa,.ilel1og/'OI.I"°
cwr~o1te l)efpendlcul-11 10 ground
\...._'-A C,..,a l MN n Mecl l1n s. Dev Min Max Co,r. Coe f.
: : - : : : - ht.••
INPUT INFORMATION !KNOWN St ~~ ... =- 3,8J7 3:i 3~ l 1.1 ?O :?3 ,U .:'l' I>:•:■:, OSS',
a: ~ a-~et<HJill«'lol·,erwc,.,o.-o?,dlslaoces; gs
~ dlag rn1,tt1-1Ct- ..:oe'"'~1e'll ol p,,,Oe;t1 an c,•., cllslarx.o! s
«:C..letahoo ,1' gr~ty Low Hi&h
c~::f·
~ ... .1•
h•,ght of l)e(!HtnMl ceNe· o# gr¥tfl.y at launc.tl t
dlstanc• c.ft,_, ofveh,ck- at undcrm soeed
S"' CI l"
)6)9
~ I 3SJ.(I
4063
~ CJ
n1..i lp,ted ll\4f'llc ..
Cl J!lJS .so,
l'lllbMtPffd'A..tl!Ce
"-distanc" ol p,Klestnan h-om lflll1al contact 10 launch
rat10 of ~de1tn.an Sp@&d tc ,~h,cle speed al time of aunch
~... Mlgle of launch of ptOtstnin r,,at,.e 10 :w. .111.1r. Monte Carlo Results
e.e; roac ~ad" anglti
'"'pulso> l,illO k,1 P"<h?Sln,lrH,-ound ,111pacl 2'0 00160
mas-.ofwh,de ... e,ghl lg 00140
100
t> •'·" mass of pedutnan we,ght 9 00120
I SO 00100 f
OUTPUT IN FORMA TION ! UNKNOWN S) OOOSJ 1
v,,. 54.97 "'' ,elocrt:,· ol ,.h,cl, 11i.e11rrip,acl wnh pedestnan 100 00060 1
S4.97 fl,• 111111ad spHd of pe(IHlll,111 000<0
ll-091 of pe(IHINl'I lhfow la...nch to 9'0\lncl impact
so
l0.91 ft oooio
0.6' ' ttme &om 111-.pact lo p,i!(li'stn.ui ,._1,al comae.I ...,,h 91ouo<1 00000
0.6T ft ~st·1., 9four'IO c~act di~1anu impact 10 ,est ~;::3;!;:;::;~~;'.:~~:g~::~:;~:;~~~
76.58 II tt>,o• <1,st.aoc, tcta, d-stance from ,nit.al cootact to Pf'destrian ,ut
.,. ...... "" ... "' .................................................... . .
......
,c,c~,c,-,._,.._ . . . . . . . . . . . 0,0,0,0,0,00000 -

'· ....
2.6!>

4.1~ II
tcta hm• d t r " of pe-1.stran 1'111.1.1 con1ac1 to :tst
11rrwol11.IYl"lol·~hK•,.10uMfrorn,rM:,alcon1a:110s:•s
cbtaoc;.e 011,~1 of \'Offi,de ....Ch peoesman :Oflta<:I
Yoo

67.07 II dlS!ark:f of lrM, cf ,9t,,cle ""'-h u!\16cm, C!Kelerat,oo .i.

S: ~s- • S. tota· distinct dlr~.•· ot~eh,cl•
71.12 II
Cumulative Probability
2.5J ,Ml,cletr~llm. 1t1it.1acontac11oru1
5.J6 ft 01,ti.•·1c. bltt .. te'I r.st 00sitt0ns of ,&hocl& and pedestr,.n 11
l
I OS

1 06
~ 04

0'

...
:
~
: :
......
0
. . ~:;;:~~:;;~:gg~:
: ; = =: : = ~ ~ ~ ~
C,, 0,
0
0 0 0 0 0
0
..,.

,.
Analysis model Reconstruction model
Analysis of pedestrian Throw Distance from Initial Conditions Calculation of vehicle initial speed from throw distance

9
 The incident occurred at ~2:20 AM on June 10, 2021
• Date of Inspection 28th Jan 2022
• There is no street lighting in area of incident.
• The measured light levels in the area of collision:
• vertical - 0.07 to 0.24 lux average
• Horizontal - 0.02 lux average
• Artificial illumination is required to illuminate
terrestrial objects in area of collision
Pedestrian visibility and recognition is restricted in the area of the collision

11
 Shown Object?
Nol Shown Object Beforehand **DEFAULT**

At Re{.ognition * • DEFAULT**

Experiment Type
Road or Traffic Study ** DEFAULT**

Shade of the Hazard

Dark 1.40 fc (15 Lux)
ADJ USTMENT
Check 1f some retrOfefl. or lighting (but lacking a pattern)
INFO

Object Pedest11an o, o the, o bJec.ts (incl vtc"hst that don t fit 1 o, 2 3

Location of Hazard
.
the Passenger's Side of Road
Info

Size of Hazard
Greater than 1 sq. metre (10 sq. ft.) A Pedestrian or other objects (incl. vehs) that don't fit 1 or 1. that was larger than 1 square metre (3.3 sq.
ft.) and was equivalent to a Dark shade was stationary and on the Passenger's Side of Road. This object
did not have retroretlective materials or lights (but the object/pedestrian was not an illuminated pattern).
If stationary and dark , there was no improvement. --- This ana lysis accounts for drivers expectancy in
Stationary Object
several ways. First, this driver was not told of, or shown the hazard beforehand. Second, drivers have
Button press dist. 21.3' 1t
not implemented emergency responses unti l certain that an eme rgency exists. As is the case with real life
drivers, th is analysis assumes the driver would not respond with an eme rgency response until certain of
the hazard ( clearly discerned). Third, this analysis assumes that the recognition occured in an open road
Avg. Button-press distance = 133 ft. or in traffic.
Avg. Recognition distance= 155 ft
Recognition Distance= 14 .1 x Shade• 21.803 x Location+ 7.772 x Size· 1.869 x Lux• 29. 5 x Shown •41 .713 x Certainty+ 88 .517 + 15 .8 x Yeh• 33.2 x Odd Shape+ 9.0 x Movement if Ligh t shade
RecogrntionDistance=14.1x (1) · 21 .803x (o) • 7.772x (1) - 1.869x(15)+29.5x (o) 41.713x (1) + 88.517+15.8x (o) -33.2x (o) • 9.ox(o) = 40.6metresor,33feet

Muttart, J. W., Bartlett, W., Kauderer, C., Johnston, G., Romose,, M., Unarski, J., Barshinger, D. (2013). Determining when an obje<.t enters the headlight beam pattern of a
vehicle. (Technical pape, no. 2013-01-0787). Warrendale, PA: ~ociety of Automotive Engineers.
Muttart, J. & Romoser, M. (2009). fvaJuoting Driver Response ond Ability to Avoid <J Crash at Night. Leicester, England; Proceedings of the Institute of T1aftic Ac1..ident
Investigators [ITAi] and the European Association for Accident Research and Analysis [EVU].
on Press terminology - Many night recognition studies asked drivers to press a button, a horn, or ma ke an utterance (i.e., a b utton pr
s report when the driver pressed the button (or made a verbal utte rance) after recognizing the object. Olson (2003, 2010) sugges
IPATH INTRUSION ~
1 s. Hazard & Appro Response Unknown ' " DEFAULT' 0 ~ Passion D. Lucas
14. Road/ HI Fidelity Sim *** DEFAULT** 3
Driving
3 Initial Speed 45.0 mph
3.00 deg r Calculate Eccentricity
IBraking Response 3
1. From Next Lane (TTC <3s.)
I2. Night i_]~
1. Subj did not discern other unit stop I 1. Response to one object ..i:J ~
I0. SV Not Turning iJ 1,.Less info (i.e. straight road) iJ ~ Avg. Deceleration 0.70 Gx
r--------------~ r Check if hovering brake u .. I
13. PRT Incl. .25-.3 s Latency (Pass. Car / ti] ~
Braking Adj,. (413 x Tr)+ 30E t 224Lt + 7160 - 496Tp - 164M + 261Tn + 350(0 · n) .. 7 eq 1 Response Distance = - 1.9 x 45 x 1.467
0 + (4 ~3x-3) + 30x3 + 224x2 + n6x1 · 496x1 · 164x1 + 261)({) + 350 X (1 -1) + 7 eq 2 Average Response Dist. 125 feet
85th percenti.le response - 85th percentile response Dist. 171 feet
AVERAGE PRT 1.9 sec 2.6 sec Ind ivi duals
-~
[ asth percentile response
Equation 1.8 sec
Min Avg Max Avg Time to stop= (2*d/A)"0.5 = 2.9 seconds
Distance = (V x conv)"2 I (2 x A)
Distance to stop= 96.7 feetl
!Resp to Pedestrian 1.9 Sec 1.6 Sec 2.6 Sec
Weighted average of 10 on-point studies of response to pedestrian path intrusions TOT. STOPPING DIST. 221.7 feet
85th %ile STOPPING DIST. 267.7 feet
 I PATH INTRUSION ~
~ Is.
RESPONSE TO PATH INTRUSION
Hazard & Appro Response Unknown '**DEFAULT'" ~
Passion D. Lucas
~ [ 4. Road/ HI Fidelity Sim *"DEFAULT** 3 Passion D." Lucas
~ [ 1. Driving 3 Initial Speed 45.0 mph
~ 3.00 deg r Calculate Eccentricity
IBrake & Steer Response 3
~ 1. From Next Lane (TTC <3s.) ..- [ 2. Night
3~ Lateral Dist To Avoid 3.0 ft.

~ 11. Subj did not discern other unit stop iJ [1. Response to one obj ect
3~ Avg . Lat. Friction (Gy) 0.18 Gy (See Lat . G Sheet)
~ Io. sv Not Turn ing 3 1. Less info (i.e. straight road)
3~ Avg . Deceleration 0.45 Gx
~----------------, r
~
Check if hovering brake
~ 13. PRT Incl. .25-.3 s Latency (Pass. Car / ri ]
Braking Adj+ (413 x lir) + 30E + 224U + 7160 - 496Tp - 164M + 26 l Tn '> 350(0 - 1) + 7 eq 1 Response Distance = - 1.9 x 45 x 1.467
0 + (413 x 3) + 30x3 + 224x2 + 716x1 - 496x1 - 164x1 rt 261.xO + 350 x O - 1) + 7 eq 2 Average Response Dist. 125 feet
85th percentile response - 85th percentile response Dist. 171 feet
AVERAGE PRT 1.9 sec 2.6 sec Individuals
-~
[ asth percenti le response
Equation 1.8 sec
Min Avg Ma·x Avg Time to Steer= (2*d/A)"0.5 = 1.02 seconds
Distance= V x t x conv . - 0.5 x g x f x t"2
Distance To Steer= 59.8 feet!
Resp to Pedestrian 1.9 Sec 1.6 Sec 2.6 Sec
Weighted average of 10 on-point studies of response to pedestrian path intrusions TOT. STEERING DIST. 184.8 feet
85th %ile STEERING DIST. 230.8 feet

15