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 the trial magistrate’s verdict sustaining the violation of R.I.G.L. 1956 § 31-22-22 (safety belt use). The Defendant argued that the trial judge erred by limiting his cross-examination of the Officer. The District Court noted, however, that the record showed that the Defendant was able to conduct cross-examination and did not place on the record any additional questions he wanted to pose. The District Court further held that since the issue was not properly preserved for appeal, the Panel correctly declined to consider the issue. Accordingly, the Court sustained the violation against the Defendant.

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