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/Probable Cause

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). The Court held that, despite the defendant’s argument that the officer’s reasonable suspicion was faulty as her medical condition rendered her unable to perform field sobriety tests, “reasonable suspicion can be based on the officer’s observation of the motorist’s vehicle while in operation; such as swerving from lane to lane or other ‘erratic movements of [the vehicle.]’” State v. Jenkins, 673 A.2d 1094, 1097 (R.I. 1996); State v. Bruno, 709 A.2d 1048, 1050 (R.I. 1998). Since the field “sobriety tests were just one factor used by [the officer] to make his determination that [the defendant] was intoxicated,” the violation was sustained.

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