RI District Court and Traffic Tribunal Case Law

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Bruce Bartels v. State of Rhode Island, A.A. No. 13-164 Procedure

Defendant appealed the decision of the Appeals Panel sustaining the violations of R.I.G.L. 1956 § 31-27- 2.1 (refusal to submit) and 1956 § 31-22-21.1 (open container). Defendant claimed the magistrate erred by admitting hearsay evidence because he allowed the citing officer to testify regarding statements the defendant had made about the incident. The District Court concluded the officer’s testimony regarding the defendant’s statements were not hearsay because they fell within Rule 801(d)(2)(A) as they were the statements of a party-opponent. Accordingly, the Court affirmed the decision of the Appeals panel sustaining the violation.

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