RI District Court and Traffic Tribunal Case Law

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City of Providence v. Blake Barrie, C.A. No. M14-0010 (June 30, 2015)

City of Providence v. Blake Barrie, C.A. No. M14-0010 (June 30, 2015).pdf
Appeals Panel
06/30/2015
City of Providence v. Blake Barrie, C.A. No. M14-0010 (June 30, 2015)

Appellate Procedure

The Defendant appealed from his guilty plea to the charged violation of R.I.G.L. 1956 § 31-14-2 (prima facie limits). The Panel held that the Defendant improperly appealed because a guilty plea signified a waiver of the right to appeal the violation. The Panel explained that the Defendant could have filed a motion to vacate his guilty plea before the sentence was levied, or, failing that, could have filed a motion for relief from judgment with the trial court. Accordingly, the Panel determined that the Defendant’s appeal of the guilty plea was improper.

City of Providence v. Blake Barrie, C.A. No. M14-0010 (June 30, 2015).pdf

Appeals Panel
06/30/2015
City of Providence v. Blake Barrie, C.A. No. M14-0010 (June 30, 2015)

Due Process

The Defendant appealed the validity of his plea to the charged violation of R.I.G.L. 1956 § 31-14-2 (prima facie limits). The Defendant argued that the trial judge coerced him into entering a guilty plea because he informed the Defendant that his license would be suspended if he proceeded to trial. The Panel pointed out that the Defendant was informed only of the possibility of suspension after trial before the Defendant entered a guilty plea. The Panel held that the Defendant knowingly, intelligently, and voluntarily pled guilty after the trial judge provided him with sufficient and accurate information. Accordingly, the Panel upheld the trial judge’s decision to sustain the charged violation.

City of Providence v. Blake Barrie, C.A. No. M14-0010 (June 30, 2015).pdf