RI District Court and Traffic Tribunal Case Law

This website is in no way affiliated with, sponsored by, or supported by the Rhode Island Judiciary, the Rhode Island District Court, or Rhode Island Traffic Tribunal.

State of Rhode Island v. Douglas Lecuivre, No. T17-0014 (April 24, 2018)

Defendant appealed a decision by a trial magistrate upholding a violation of R.I.G.L. 1956 § 31-26-4 (duty upon collision with unattended vehicle). Defendant argued that the trial magistrate improperly admitted hearsay testimony into evidence and then relied on that testimony in his decision. Specifically, defendant contends that the citing officer’s testimony regarding defendant’s statements on the day of the accident were inadmissible as hearsay. The Appeals Panel, however, noted that defendant’s statements to the citing officer were statements by a “party opponent,” meaning they fall under an exception to the hearsay rule. As a result, the Appeals Panel held that defendant’s statements were admissible and not inadmissible hearsay. Accordingly, the Appeals Panel denied defendant’s appeal and upheld the trial magistrate’s decision.

Case Index