RI District Court and Traffic Tribunal Case Law

This website is in no way affiliated with, sponsored by, or supported by the Rhode Island Judiciary, the Rhode Island District Court, or Rhode Island Traffic Tribunal.

State of Rhode Island v. Erin Lawrence, C.A. T08-0049 (April 23, 2008)

The Defendant appealed the trial magistrate’s decision to sustain the charged violation of R.I.G.L. 1956 § 31-27-2.1 (refusal to submit to chemical test). The Defendant argued that there was a lack of evidence to find that she operated the vehicle because there was no witness who testified as to her operation and there was no credible admission that she operated the vehicle. Additionally, the Defendant argued that the trial magistrate’s finding of operation violated the corpus delecti rule by allowing into evidence the motorist’s uncorroborated admission of operation. The Panel held that it did not need to address the corpus delecti argument because it is only applied in criminal cases. The Panel also held that there was evidence that made it apparent to the Officer that the Defendant operated of the vehicle because she was the registered owner of the vehicle with front-end damage and she made no mention of another operator. Accordingly, the Panel upheld the trial magistrate’s decision to sustain the charged violation.

Case Index