RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Jason Patterson M22-0001 Radar/Laser Calibration

Defendant appealed the Trial Magistrates decision sustaining a charged violation of G.L. 1956 § 31-14-2, Speeding. At the trial, a Patrolman for the Cumberland Police Department testified that he was “stationed on a fixed traffic post located on Abbott Run Valley Road.” The Patrolman testified to seeing the Defendant traveling at what he believed to be a “higher rate of speed than the posted twenty-five (25) miles per hour speed limit.” He used his radar and determined that the Defendant was traveling at 37 miles per hour. The Patrolman testified that he was trained on how to use a radar unit on how “to estimate the speed of a moving vehicle without the use of radar.” He testified to calibrating the radar both externally and internally and stated that the unit was working in good condition. He also moved into evidence a certificate of the radar’s accuracy, indicating that the radar had been certified less than a year before the stop.  The Defendant argued that he was targeted for having Texas plates and also noted that the area in which he was traveling was “hilly,” which would contribute to his speed. The Trial Judge found the Defendant guilty. Defendant appealed. 

The Appeals Panel upheld the Trial Court’s decision. The Appeals Panel relied upon State v. Sprague, 322 A.2d 36 (1974), and held the requirements had been met as the Patrolman had testified as to the “radar’s accuracy” and provided evidence of sufficient training in the use of the radar. Due to these reasons, the Appeals Panel sustained the charged violation of speeding. 

 

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