RI District Court and Traffic Tribunal Case Law

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Merimee Christopherson v State of Rhode Island, A.A. No. 18-186 (July 11, 2019)

Defendant appealed a decision of the Appeals Panel sustaining a violation of G.L. 1956 § 31-22-31 (mobile telephone usage by motor vehicle operators). At trial, the citing officer testified that “there was no doubt in his mind that [Defendant] had a cell phone in her hand” while she was driving. Conversely, Defendant testified that she did not use her phone while driving, and she supported her testimony with her phone’s call logs. But the trial judge concluded that Defendant failed to establish the call logs’ authenticity. Moreover, the trial judge found the police officer’s testimony to be credible, and, therefore, the trial judge found Defendant guilty. At the District Court, Defendant argued that the Appeals Panel’s decision to affirm the trial judge’s decision was clearly erroneous because the trial judge failed to afford the proper weight to Defendant’s testimony and the call logs that she presented. Both issues regard credibility determinations, and it is well established that the District Court may not substitute its “judgment for that of a trial magistrate as to the weight of the evidence on questions of fact.” The trial judge saw and heard the witnesses live, and only he could properly “evaluate their demeanor.” As such, the District court held that the Appeals Panel’s deference to the trial judge was not clearly erroneous. Accordingly, the District Court affirmed the Appeals Panel’s decision.

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