RI District Court and Traffic Tribunal Case Law

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City of Providence v. Christina Machado, C.A. No. T13-0019 (August 19, 2013) Reasonable Grounds

Defendant appealed the decision of the trial magistrate sustaining the violation of R.I.G.L. 1956 § 31-27-2.3 (refusal to submit to preliminary breath test) and § 31-27-2.1 (refusal to submit to chemical test).  Defendant claimed that the officer did not have reasonable grounds to believe she had operated a vehicle while under the influence.  The officer never observed the defendant driving, having arrived at the scene of an accident in which the defendant was involved, and did not perform any field sobriety tests.  The Court held that the officer had reasonable grounds under the “totality of the circumstances” because the defendant had bloodshot and watery eyes, had slurred speech, emitted a strong odor of alcohol, and admitted to consuming two alcoholic drinks earlier in the evening.  Accordingly, the Panel sustained the charged violations.

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