RI District Court and Traffic Tribunal Case Law

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Town of East Greenwich v. Anthony Ianiero, C.A. No. M13-0014 (March 7, 2014)

Town of East Greenwich v. Anthony Ianiero, C.A. No. M13-0014 (March 7, 2014).pdf
Appeals Panel
03/07/2014
Town of East Greenwich v. Anthony Ianiero, C.A. No. M13-0014 (March 7, 2014)

Identification

Defendant appealed the decision of the trial magistrate sustaining the violation of R.I.G.L. 1956 § 31-14-2 (prima facie limits).  Following Town of North Kingstown v. Philip Dey, C.A. No. T13-0008, September 10, 2013, R.I. Traffic Trib. (holding that in-court identification can be inferred from all the facts and circumstances presented to the finder of fact), the tribunal found that the trial magistrate was satisfied that the defendant had been identified as the operator of the vehicle because during testimony, the officer referred to him as the operator of the vehicle.  Thus, the tribunal held that the trial magistrate’s decision was supported by the reliable, probative, and substantial evidence, and that the defendant was the operator of the vehicle. Accordingly, the Appeals Panel affirmed the decision of the trial court sustaining the violation against the defendant.

Town of East Greenwich v. Anthony Ianiero, C.A. No. M13-0014 (March 7, 2014).pdf

Appeals Panel
03/07/2014
Town of East Greenwich v. Anthony Ianiero, C.A. No. M13-0014 (March 7, 2014)

Radar/Laser Calibration

Defendant appealed the decision of the trial magistrate sustaining the violation of R.I.G.L. 1956 § 31-14-2 (prima facie limits). Following State v. Sprague, 322 A.2d 36, 36 (R.I. 1974), the tribunal held that an officer must be trained to use a radar device and the device must have been calibrated within a reasonable time. Here, the officer testified that he had been trained in the use of a radar device at the Academy and that his radar device had been calibrated both internally and externally on the day the citation was issued. Accordingly, the Appeals Panel affirmed the decision of the trial court sustaining the violation against the defendant.

Town of East Greenwich v. Anthony Ianiero, C.A. No. M13-0014 (March 7, 2014).pdf