RI District Court and Traffic Tribunal Case Law

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Craig Huntley v. State of Rhode Island, A.A. No. 2010-0157 Operation of Motor Vehicle

Defendant appealed the decision of the Appeals Panel sustaining the violation of R.I.G.L. 1956 § 31-27-2.1 (refusal to submit). Defendant argued that the officer lacked reasonable grounds to believe that he had operated a vehicle while under the influence because the officer never observed the defendant drive, did not administer field sobriety test, and only observed the defendant standing outside of the vehicle when he responded to the scene. The District Court held that the officer had reasonable grounds to believe that the defendant had operated a vehicle while under the influence because the officer observed the defendant standing “bloodied” next to a vehicle that had recently been in an accident, he admitted that he had been the driver of the vehicle, he admitted to consuming alcohol, he had water and bloodshot eyes, and he emitted an odor of alcohol. Accordingly, the Court sustained the violation against the defendant.

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