RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Christopher Hook, No. T18-0021 (February 25, 2019)

Defendant appealed a trial judge’s decision sustaining a violation of G.L. 1956 § 31-14-2 (prima facie limits). At trial, a police officer testified that the Defendant admitted to speeding. Moreover, the officer satisfied the Sprague requirements by testifying to: (1) the radar unit’s operational efficiency; and (2) his own training and experience in the use of a radar unit. See State v. Sprague, 113 R.I. 351, 355-57 (1974). The trial judge found the officer’s testimony to be credible.

On appeal, Defendant argued that the trial judge’s decision was clearly erroneous. But the Appeals Panel “lacks the authority to assess witness credibility.” Link v. State, 633 A.2d 1345, 1348 (R.I. 1993) (citing Liberty Mut. Ins. Co. v. Janes, 586 A.2d 536, 537 (R.I. 1991)). As such, the Appeals Panel held that the trial judge’s decision was not clearly erroneous. Accordingly, the Appeals Panel affirmed the trial judge’s decision.

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