RI District Court and Traffic Tribunal Case Law

This website is in no way affiliated with, sponsored by, or supported by the Rhode Island Judiciary, the Rhode Island District Court, or Rhode Island Traffic Tribunal.

State of Rhode Island v. Erin Lawrence, C.A. T08-0049 (April 23, 2008)

The Defendant appealed the trial magistrate’s decision to sustain the charged violation of R.I.G.L. 1956 § 31-27-2.1 (refusal to submit to chemical test). The Defendant argued that the trial magistrate should have considered the Officer’s sworn report as substantive evidence of his prior inconsistent statements and erred in finding that the Officer’s sworn reports had no viability after the preliminary suspension hearing. The Panel held that the trial magistrate did not err because the omissions in the Officer’s sworn report did not rise to the level of prior inconsistent statements and because the Officer’s sworn report was admitted for the limited evidentiary purpose of showing compliance with § 31-27-2.1 Accordingly, the Panel upheld the trial magistrate’s decision to sustain the charged violation.

Case Index