RI District Court and Traffic Tribunal Case Law

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City of Providence v. Dominiqua Newkirk, No. T15-0028 (August 23, 2016)

Defendant appealed the decision of the trial court sustaining the violation of R.I.G.L. 1956 § 31-14-3 (“conditions requiring reduced speed”). Defendant argued that that § 31-14-3 does not meet the constitutional test of reasonable certainty as set forth in State v. Scofield, 138 A.2d 415 (R.I. 1958). The Appeals Panel held that § 31-14-3 does withstand the scrutiny of the constitutional test of reasonable certainty because the statute’s language is definite enough and incorporates § 31-14-1 by reference. § 31-14-1 states that a motorist must reduce his or her speed when approaching hazards like an intersection. These two statutes read together fairly appraise motorists of when they must reduce their speeds.  Accordingly, the trial court’s decision was affirmed.

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