Obedience to Devices

The Defendant appealed the Trial Magistrate’s decision sustaining the charged violation of G.L. 1956 § 31-13-4, Obedience to traffic devices. A police officer testified that he observed a vehicle stopped at the exit of a shopping plaza sit through three green light cycles without proceeding through the light. After the vehicle eventually exited the parking lot, the officer conducted a traffic stop. Although the officer conceded that there were no vehicles behind the Defendant, he charged him with violating “obedience to traffic devices” on the theory that he was “obstructing the normal flow of traffic.” The Defendant argued that “there is nothing in the general law which mandates that you must go” when the light turns green. Ultimately the Trial Judge found the defendant guilty, holding that “it can be inferred that it is mandated to proceed, if you don’t, your presence there is going to disrupt the normal flow of traffic as it did here.”  The Defendant appealed, arguing that the Trial Magistrate “incorrectly interpreted § 31-13-6(1)(i).” 

RIGL § 31-13-6(1)(i) provides that “[v]ehicular traffic facing a circular green signal is permitted to proceed straight through or turn right or left or make a U-turn movement.” The Defendant here argued that the language of the statute is permissive and that nothing in the statute requires a motorist to proceed through a green light. The Appeals Panel noted that the Supreme Court of Rhode Island has held that when a statute is ambiguous, the statute must be interpreted “literally and [a court] must give the words of the statute their plain and ordinary meanings.” Additionally, the Appeals Panel noted that the Rhode Island Supreme Court has held that “under no circumstance will this Court ‘construe a statute to reach an absurd result.’” The Appeals Panel held that to interpret the statute as permissive and not mandatory, as suggested by the Defendant, would lead to an absurd result and, therefore, sustained the charged violation. 

 State of Rhode Island v. Jonathan Jamiel T20-0009 (January 15, 2021).pdf