Speedometer Calibration

Defendant appealed the decision of the trial court sustaining the violation of R.I.G.L. 1956 (“prima facie limits”). Defendant argued that Trial Magistrate erred in concluding that the two prongs of State v. Machino, 340 A.2d 128 (R.I. 1975), had been satisfied. State v. Machino requires the prosecution to prove that  a speedometer used to clock a motorists was tested against another speed-testing standard and that the speedometer was operating properly at the time of the alleged violation. At trial, the Trooper testified that his speedometer was calibrated 14 days before the citation and was found to be in good working order. Therefore, the Trial Magistrate’s finding that the two prongs of State v. Machino had been satisfied was not an error. In addition, the Appeals Panel noted that State v. Machino requires the defendant to raise at trial any argument concerning the calibration of the speedometer. Accordingly, the trial court’s decision was affirmed.

State of Rhode Island v. Brett Gralinski, No. T16-0007 (July 11, 2017).pdf