RI District Court and Traffic Tribunal Case Law

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Carol Brown v. State of Rhode Island, A.A. No. 18-143 (March 25, 2019)

Defendant appealed a decision of the Appeals Panel sustaining a violation of G.L. 1956 § 31-26-5 (duty in accident resulting in damage to highway fixtures). The police responded to a call stating that a vehicle had struck a road sign. One officer found the damaged sign, and another officer found a vehicle that had damage consistent with striking a sign and matched a witness’s description driving away from the scene of the accident. Defendant set forth several factual arguments asserting that the evidence against her was insufficient to sustain the charged violation. When dealing with factual matters, the District Court’s “sole function is to decide whether the trial magistrate’s verdict was supported by competent evidence.” The District court held that the evidence against Defendant was sufficient to meet a clear and convincing standard of proof, and, as such, the Appeals Panel’s ruling was not clearly erroneous. Accordingly, the District Court affirmed the decision of the Appeal Panel.

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