RI District Court and Traffic Tribunal Case Law

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City of Providence v. Stephen Gill, No. M16-0003 (April 17, 2018)

Defendant appealed a decision by a Providence Municipal Court Judge sustaining a violation of R.I.G.L. 1956 § 31-13-4 (Obedience to devices). An automated traffic camera captured a photograph of Defendant’s vehicle traveling through an intersection after the traffic light signaled red. At his arraignment Defendant attempted to plead not guilty, but the judge, after viewing a video, refused to accept the not guilty plea and instead entered a plea of guilty. Defendant argued that his procedural due process rights were violated because the lower court judge did not accept his not guilty plea or provide him with the right to present a defense. The Appeals Panel further noted that because no witness testified on behalf of the Providence Police Department, Defendant was deprived of any opportunity for cross-examination. Accordingly, the Appeals Panel found that Defendant did not receive a fair and adequate legal proceeding that satisfied the guarantees of procedural due process. The Appeals Panel granted Defendant’s appeal and dismissed the charged violation.

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