Operating an Unregistered Vehicle

Defendant appealed the decision of the Appeals Panel sustaining the violation of R.I.G.L. 1956 § 31-3-1 (operation of unregistered vehicle). The Court, reviewing the record, found no testimony on the part of the arresting officer pertaining to whether the defendant knew the vehicle was unregistered. The defendant possessed a transporter plate for the vehicle but none of the additional paperwork necessary to use a transporter plate. The defendant worked for Specialty Auto Sales and testified that the registration of the plate would go through them. Under Albanese v. Providence Police Dep’t, 711 A.2d 651 (RI 1998), the defendant must possess knowledge that the vehicle is unregistered. As such, the Court reversed the Appeals Panel decision because there was no probative, reliable, and substantial evidence the defendant knew the vehicle had been inappropriately registered by his employer.State of Rhode Island v. Louis Depina A.A. No. 12-170.pdf