RI District Court and Traffic Tribunal Case Law

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William Martin-Hannon v. Town of Hopkinton, A.A. No. 14-122 (March 18, 2015)

Defendant appealed the judgment of the Appeal Panel affirming the trial magistrate’s verdict sustaining the violation of R.I.G.L. 1956 § 31-22-22 (safety belt use). The Defendant argued that the Municipal Court did not have subject-matter jurisdiction over him because he is a “non-corporate person” not involved in commerce and not a United States citizen. The District Court noted that since the seat-belt use statute is rationally connected to the goal of highway safety and promoting the public welfare, the statute is a constitutional use of policy power. The District Court held that because the Defendant was operating a vehicle in Rhode Island, he is subject to the Rules of the Road. The Court noted that he had succumbed to the Rules by obtaining a Rhode Island operator’s license and by registering his vehicle Rhode Island. Therefore, because the offense was properly created through the police power of the State and the Defendant, by operating in the state, was subject to its Rules, the argument that the Defendant was not subject to the law had no weight. Accordingly, the Court sustained the violation against the Defendant.

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