RI District Court and Traffic Tribunal Case Law

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Daniel Buck v. Town of Westerly & State of Rhode Island, A.A. No. 15-33 (June 8, 2016)

Defendant appealed the Rhode Island Traffic Tribunal’s Appeals Panel decision sustaining defendant’s conviction under R.I.G.L. § 31-14-2 (“prima facie limits”). Defendant argued that external calibration is required for radars under State v. Sprague, 322 A.2d 36 (R.I. 1974). Following Sprague, which requires only proof that “the operational efficiency of the radar unit was tested within a reasonable time by an appropriate method,” id. at 39-40, the District Court held that external calibration is not required.  Accordingly, the court affirmed the Appeals Panel decision sustaining the defendant conviction.

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