RI District Court and Traffic Tribunal Case Law

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James Folan v. State of Rhode Island, A.A. No. 14-0021 (February 25, 2015)

Defendant appealed the judgment of the Appeals Panel affirming a municipal court judge’s verdict sustaining the violation of R.I.G.L. 1956 § 31-22-22 (safety belt use). The Defendant argued that he was prejudiced by repeated scheduling miscues, which caused him to have to return to court multiple times before being afforded his trial. The District Court noted that the Panel found that the scheduling errors violated neither the right to due process, because he was afforded a trial, nor the right to a speedy trial, which is only applicable in criminal cases. The District Court, however, held that the Panel should have addressed the Defendant’s procedural complaint by the standards enumerated in Rule 26(b) of the Traffic Tribunal Rules of Procedure because the court was adjudicating a traffic offense. Despite the error in applicable standard, the District Court held that the case did not need to be remanded because the Defendant had not proven prejudicial delay within the case. Accordingly, the Court sustained the violation against the Defendant.

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