08/13/2019
Defendant appealed a trial judge’s decision sustaining a violation of G.L. 1956 § 31-15-11 (laned roadway violations). A police officer responded to the scene of a reported motor vehicle accident between Defendant and a city truck. At trial, the city truck driver testified that he momentarily stopped at an intersection waiting for traffic to clear before making a left-hand turn. In contrast, Defendant testified that the city truck was parked on the side of the road which led to her attempting to go around the vehicle. As Defendant attempted to pass the city truck, the truck began to turn, and the two vehicles collided. On appeal, Defendant argued that there was insufficient evidence in the record to support the trial judge’s decision.
To sustain a violation of § 31-15-11, the evidence must show that (1) the roadway is divided into at least two lanes; (2) the vehicle did not, as nearly as practical, operate entirely within a single lane; and (3) the vehicle moved from the lane at a time that the move could not be safely made. Here, the Appeals Panel held that the trial judge’s decision was supported by legally competent evidence. Specifically, testimony presented at trial established the three aforementioned elements. Accordingly, the Appeals Panel affirmed the trial judge’s decision.
State of Rhode Island v. Angela Martin, No. M18-0019 (August 13, 2019).pdf