RI District Court and Traffic Tribunal Case Law

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City of Providence v. Emilio Taylor, C.A. T08-0097 (November 5, 2008)

The Defendant appealed the trial judge’s decision to sustain the charged violations of R.I.G.L. 1956 § 31-16-5 (turn signal required) and R.I.G.L. 1956 § 31-22-22 (safety belt use). The Defendant, who appeared pro se, argued that the trial judge violated his due process rights by not advising him of his right to cross-examine the Officer. The Panel noted that a pro se litigant is expected to become familiar with the rules of procedure and that, had the Defendant reviewed the rules of procedure, he would have realized that he was entitled to cross-examine the Officer. Nonetheless, the Panel held that the Defendant was deprived by not being afforded a meaningful opportunity to cross–examine the Officer as to the seat-belt violation. Accordingly, the Panel remanded the seat-belt violation to allow the Defendant the opportunity to cross-examine the Officer.

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