RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Patricia Sargent C.A. No. T10-0056 Reasonable Grounds

Defendant appealed the decision of the trial magistrate sustaining the violation of R.I.G.L. 1956 § 31-27-2.1 (refusal to submit to a chemical test). Defendant claimed that the officer lacked reasonable grounds to believe that she had operated a vehicle under the influence because she informed the officer that her medical condition affected her performance on the field sobriety tests. The Court held that reasonable grounds existed for the officer to believe that the defendant had operated a vehicle under the influence because the defendant exhibited numerous indicia of intoxication in addition to her performance on the field sobriety tests, including that she had bloodshot and watery eyes, she had an unsteady gate when exiting the vehicle, she drove erratically and nearly collided with the officer’s vehicle, and she emitted an odor of alcohol. Accordingly, the Court sustained the violation against the defendant.

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