RI District Court and Traffic Tribunal Case Law

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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 the Officer’s reports were inaccurate and unreliable because they listed different accident times. The Panel held that the defects in the Officer’s report did not rise to the level of a reversible error and the divergent accident times were likely the result of the lack of a third-party witness to the accident. The Panel continued that, though the exact time of the accident may be difficult to discern, the time had little bearing on whether the Officer had reasonable grounds to believe that the Defendant operated the vehicle while intoxicated and refused a chemical test. Accordingly, the Panel upheld the trial magistrate’s decision to sustain the charged violation.

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