Reasonable Grounds/Probable Cause

The state appealed the decision of the Appeals Panel dismissing the violations of R.I.G.L. 1956 § 31-27-2.1 (refusal to submit) and R.I.G.L. 1956 § 3-8-9 (transportation of an alcoholic beverage by a minor). The state claimed that the decision of the Appeals Panel upholding the dismissal on the ground that the officers lacked reasonable grounds to believe that the defendant was operating a vehicle under the influence was in error. Additionally, the state claimed that the trial judge applied the wrong standard because she interchanged reasonable suspicion and reasonable grounds. The officers had testified that the defendant looked disheveled, had bloodshot and watery eyes, emitted an odor of alcohol, and had slurred speech. The District Court held that the trail judge’s decision that the officer lacked reasonable grounds was not in error because her decisions regarding credibility were supported by competent evidence on the record as she watched the video tape of the defendant’s stop multiple times, went to the scene of the stop, and considered to the officer’s testimony. Furthermore, the Court held that the trial judge’s application of a reasonable suspicion standard was immaterial and amounted to harmless error. Reasonable grounds is the proper standard for assessing a refusal case, and because reasonable suspicion is a lesser standard than reasonable grounds, the state was not prejudiced when it failed to prove on a lesser standard that the officer had reasonable suspicion to believe that the defendant had operated a vehicle under the influence. Accordingly, the Court upheld the dismissal of the violations against the defendant. State of Rhode Island v. Zachary Flanders, A.A. No. 03-134.pdf