RI District Court and Traffic Tribunal Case Law

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Jared Bisordi v. State of Rhode Island, A.A. No. 2014-092 (June 1, 2015)

Defendant appealed the judgment of the Appeals Panel affirming the trial magistrate’s verdict sustaining the violation of R.I.G.L. 1956 § 31-27-2.1 (refusal to submit to a chemical test). The Defendant argued that the trial magistrate erred in finding that the Trooper had reasonable grounds to believe that he had been driving under the influence of alcohol because the Trooper never saw him drive. The Court here held that the Trooper had reasonable grounds to believe that the Defendant had operated his vehicle because the Defendant himself had told the Trooper that the Defendant had driven. The Court noted in a footnote that the corpus delicti rule, which might prevent the introduction into evidence of this admission, does not apply in civil cases. Accordingly, the Court upheld the decision to sustain the violation.

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