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 her statements to the police should have been suppressed because she was detained at the time of her questioning at the scene of her accident and should have been informed of her rights. The Panel held that no admonition of the Defendant’s rights were required until the Defendant was handcuffed and the Officer placed her in the police cruiser. The Panel observed that the record indicated that the Officer read the Defendant her rights once she was detained. Accordingly, the Panel upheld the trial magistrate’s decision to sustain the charged violation.

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