Due Process

Defendant appealed the decision of the trial magistrate sustaining the charged violation of R.I.G.L. 1956 § 31-22-22 (safety belt use).  Defendant argued that the trial magistrate’s decision was in violation of Defendant’s Constitutional rights because the magistrate denied his motion for a jury trial.  Specifically, Defendant argued that the Seventh Amendment to the Constitution of the United States guarantees a jury trial for civil actions when the amount in controversy exceeds twenty dollars.  The Panel explained the Seventh Amendment right to a jury trial in civil cases has not been applied to the States by the Supreme Court of the United States.  The Panel further explained that no Rhode Island Supreme Court precedent demands a jury trial in civil cases other than those cases that were based on actions triable by a jury at the time of the adoption of our State Constitution in 1842.  The Panel explained that in 1842, the motor vehicle code was not in effect.  Additionally, the Panel explained that the Rhode Island Supreme Court has considered whether a motor vehicle code violation should warrant a jury trial and held it does not.  See Calore Freight Systems, Inc. v. Dept. of Trans., 576 A.2d 1214 (1990).  The Calore Court further suggested that if an offense is of a type that should warrant a jury trial, or is similar to an offense in existence in 1842, a jury trial may be appropriate.  Id.  However, the Panel explained that no similar offense existed in 1842, and that because the fines imposed in a motor vehicle code violation are definite and not subject to discretion, there is limited need for a jury.  The Panel held that there is no right to a jury trial for a motor vehicle code violation.  Accordingly, the Panel sustained the charged violation. 

State of Rhode Island v. John Miner, C.A. No. T12-0024 (August 20, 2012).pdf