Obedience to Devices

Defendant appealed from a decision of the trial court sustaining the charged violation of R.I.G.L. 1956 § 31-13-4 (Obedience to Devices).  Specifically, Defendant argued that because the Officer testified that he was in a position on the other side of a traffic light he could not see whether her traffic light was red or yellow at the time the Defendant passed through it.  The Panel explained that police officers are allowed to presume the regularity and calibration of traffic lights.  The Panel held that the trial judge properly credited the officer’s testimony that he made a presumption about the color of the light facing defendant based on the color of the light facing the opposite direction.  Accordingly, the Panel sustained the charged violation.

Town of Warren vs. Heidi Jamiel, C.A. No. T12-0052 (April 9, 2013).pdf