RI District Court and Traffic Tribunal Case Law

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City of Pawtucket v. Jarred Lynch, C.A. No. T12-0032 (April 17, 2014)

Defendant appealed from the trial magistrate’s decision to sustain the charged violations of G.L. 1956 § 31-15-11, “laned roadway violations” and § 31-27-2.1, “refusal to submit to a chemical test.”  Initially, the City of Pawtucket appointed a special prosecutor due to a potential conflict of interest.  Subsequently, the special prosecutor dismissed the charges.  The Pawtucket Police then re-filed the charges, and the resulting trial ended in a conviction on both charges.  The Defendant appealed, claiming that the trial magistrate’s decision to deny his motion to dismiss was an error of law.  Specifically, Defendant claimed that various conflicts of interest by the Pawtucket Police Department amounted to a violation of his due process rights that should have resulted in a dismissal of the charges.  The Panel looked to various Rhode Island, Connecticut, and U.S. precedent to explain that to succeed on a claim of bias under the Due Process clause, as an initial matter, the defendant must overcome a presumption of honesty and integrity by the decision maker.  Furthermore, in an administrative proceeding like the Traffic Tribunal, Due Process requires the opportunity to be heard in a meaningful manner in front of a neutral decision maker.  Finally, the defendant must show not only prosecutorial misconduct, but also that the misconduct resulted in unfair prejudice to the defendant.  The Panel then looked at the record and found that the defendant made only general accusations of impropriety and failed to identify any specific misconduct committed by the Pawtucket Police Department.  Moreover, the defendant did not impute any misconduct to the trial magistrate and did not show that the alleged misconduct resulted in any unfair prejudice.  The Panel held that the Defendant did not overcome the presumption that he received a full hearing before an impartial and disinterested tribunal.  The Panel explained that it was satisfied that the requirements of due process were met and held that the trial magistrate’s decision to deny the Defendant’s motion to dismiss was not an error of law or an abuse of discretion

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