RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Tayla Northup, No. T19-0016 (January 9, 2020)

Defendant appealed decision of the trial judge sustaining a violation of G.L. 1956 § 31-14-2 (prima facie limits). Defendant argued that the prosecution did not meet its burden of proof because the testifying officer failed to state that she possessed training and experience in the use of a radar unit. In order for a radar unit reading to be admissible at trial, the testifying officer must state that the unit was tested within a reasonable time by an appropriate method, and the officer must set forth her training and experience in the use of a radar unit. State v. Sprague, 322 A.2d 36, 39-40 (R.I. 1974). The Appeals Panel held that the prosecution did not meet its burden of proof because the testifying officer failed to state that she possessed training and experience in the use of a radar unit. Accordingly, the Appeals Panel reversed the decision of the trial judge.

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