RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Jillian Snyder, M19-0008 (June 26, 2019)

Defendant appealed a trial judge’s decision sustaining a violation of G.L. 1956 § 31-13-4 (obedience to traffic devices). A police officer observed a vehicle proceed through a red light. At trial, while offering an explanation in mitigation, Defendant admitted to proceeding through a red light.

On appeal, Defendant argued that the trial judge’s decision was erroneous because Defendant offered conflicting testimony regarding the location of the violation at trial. But it is well-established that the Appeals Panel “lacks the authority to assess witness credibility or to substitute its judgement for that of the hearing judge concerning the weight of the evidence on questions of fact.” See 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)). Moreover, Defendant and the police officer testified that Defendant proceeded through the red light. As such, the Appeals Panel held that the trial judge’s decision was supported by legally competent evidence. Accordingly, the Appeals Panel affirmed the trial judge’s decision.

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