Reasonable Grounds/Probable Cause

Defendant appealed the decision of the trial magistrate sustaining the violations of R.I.G.L. 1956 § 31- 27-2.1 (refusal to submit to a chemical test) and R.I.G.L. 1956 § 31-22-21.1 (presence of alcoholic beverages while operating or riding in a motor vehicle). Defendant challenged whether the officer had reasonable grounds to ask the defendant to submit to a chemical test where the defendant was approached by the officer while he was outside the vehicle in a parking lot. The court held that the officer had reasonable grounds to infer that the defendant had been operating a vehicle while under the influence because the defendant stated that he had been driving, he was observed “rummaging through the trunk” of the vehicle, marks on the defendant’s tires that suggested the vehicle had been operated recently, and there were “no establishments within a half mile of the parking lot where [the defendant] could have consumed alcohol after the vehicle was parked.” Therefore, the Court affirmed the decision of the trial magistrate.Town of Richmond v. Bruce Bartels C.A.T13-0021.pdf