RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Craig Huntley, C.A. No. T09-0092 (December 16, 2009) Reasonable Grounds

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 1956 § 31-15-11 (laned roadways). Defendant argued the decision of the trial magistrate was clearly erroneous because the officer did not have reasonable grounds to suspect the Defendant was operating under the influence.  Specifically, the Defendant argued the Officer did not personally observe the Defendant operating the vehicle and did not conduct any field sobriety tests at the scene and, therefore, arrested him without probable cause.  The Panel noted that the Officer came upon the scene of a horrific accident and that the Defendant admitted to being the driver of the vehicle in question, admitted to having consumed alcohol, had bloodshot watery eyes, had an odor of alcohol emanating from his breath, was weaving back and forth on his feet, and appeared to be ready to fall asleep.  The Panel also noted that field sobriety tests are not required but rather are simply one tool officers may use to obtain probable cause.  Here, the Panel noted that the Officer decided not to conduct field sobriety tests so as to not interfere with medical treatment the Defendant was receiving at the scene.  The Panel held that, based on the Defendant’s admissions and the Officer’s observations, the trial magistrate was justified in finding the Officer had reasonable grounds to suspect the Defendant of operating under the influence.  Accordingly, the Panel sustained the charged violations.

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