RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Cindy Salazar, C.A. M08-0012 (September 10, 2008)

The Defendant appealed the trial judge’s decision to sustain the charged violation of R.I.G.L. 1956 § 31-14-2 (prima facie limits). The Defendant argued that trial judge erred in finding that the Sergeant’s trial testimony satisfied the prevailing standard for admissibility of radar speed readings set forth in State v. Sprague, 322 A.2d 36  (R.I. 1974). The Panel held that although the Sergeant testified that “the operational efficiency of [his] radar unit was tested within a reasonable time by an appropriate method,” he failed to testify as to his “training and experience in the use of a radar unit.” Id. at 40. Accordingly, the Sergeant’s speed reading was inadmissible and the Panel dismissed the charged violation.

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