Defendant appealed a Trial Magistrate’s decision sustaining the charged violation of G.L. 1956 § 31-14-2 (Speeding). A Rhode Island State Trooper testified to being stationed at a “fixed radar post on Route 95 South at Exit 2” and obtaining the fixed speed of two oncoming cars going 103 miles per hour. The trooper testified that he followed the vehicles and obtained a moving radar speed on the rear car of 107 miles per hour in a 65 mile per hour zone. The driver was identified to be the defendant and a ticket was issued for speeding. The Trooper provided testimony as to his training in using a radar, noting that he had received “recertification two years prior to the hearing.” He also testified that the radar unit had been calibrated “internally and externally at the beginning of the shift.” The Defendant contested the speeding charge, claiming that he had a device in his vehicle that would alert him if he were driving at an excessive speed. The Trial Judge found the Defendant guilty and the Defendant appealed, arguing that the trooper did not provide sufficient evidence as to his training on the specific radar device that he used that day, nor did he provide proof that it was in fact the Defendant’s vehicle traveling at the excessive speed. 

The Appeals Panel upheld the Trial Court’s decision. The Appeals Panel relied on the two-prong test in State v. Sprague, 322 A.2d 36 (1974), and determined that sufficient evidence had been shown to satisfy the second prong as the trooper testified that he “had received training at the Rhode Island State Police Academy” and “recertification two years prior to the hearing.” The Appeals Panel rejected the argument that there must be evidence of training in the “specific radar unit used to obtain a vehicle’s speed.” Further, the Appeals Panel noted that the only evidence offered by the Defendant to contradict the trooper’s testimony was insufficient, as the Defendant claims that he had a device in his car that would alert to speeding but provided no “documentation as to the reliability of the device.” Therefore, the Appeals Panel found no error of law and gave deference to the Trial Judge’s decision. For these reasons the Appeals Panel sustained the charged speeding violation.