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). The officer did not provide any testimony regarding her training on the use of a radar device, a necessary requirement for the charge to be sustained, until prompted by the trial judge’s question “Did you go to school?” Defendant argued that the trial judge’s question was improper. Although a court may interrogate witnesses, judicial interrogation is limited to clarification of confusing matters for the judge or jury. State v. Nelson, 982 A.2d 602, 617 (R.I. 2009). Here, the trial judge’s question did not seek to clarify confusing testimony, but instead improperly assisted the prosecution in satisfying an element of the charged violation. Accordingly, the Appeals Panel reversed the decision of the trial judge and dismissed the violation.

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