RI District Court and Traffic Tribunal Case Law

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Kristof Toth v. RITT, A.A. No. 06-98 Double Jeopardy

Defendant appealed the decision of the Appeals Panel sustaining the violations of R.I.G.L. 1956 § 31-14-1 (reasonable and prudent speeds) and R.I.G.L. 1956 § 31-14-3 (conditions requiring reduced speeds). The Court held that the two charges could both be sustained even though the same conduct was the basis for both violations. Sustaining both of the charges did not violate the defendant’s constitutional right against double jeopardy because the statutes were sufficiently distinct. Section 31-14-1 entails the failure to maintain control resulting in a collision, whereas § 31-14-3 requires only reduced speed under certain conditions. Accordingly, the Court affirmed the decision of the trial court sustaining the violations against the defendant.

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