RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. George Delany, No. T19-0008 (July 17, 2019)

Defendant appealed a trial judge’s decision sustaining a violation of G.L. 1956 § 31-51-2.2 (stopping for school bus required—digital video). At trial, a video recording showed Defendant’s vehicle passing a stopped school bus whose red lights were activated. Also, Defendant admitted to passing the stopped school bus. On appeal, Defendant argued that the trial judge erred because there was insufficient evidence to sustain the charged violation.

Under § 31-41-2.2, a person is guilty when the evidence presented at trial shows that a school bus’s flashing red lights were activated and the driver failed to stop before reaching the school bus. Here, the video presented at trial clearly demonstrated that the school bus’s flashing red lights were activated. Moreover, Defendant admitted to passing the school bus. As such, the Appeals Panel held that the trial judge’s decision was supported by sufficient evidence. Accordingly, the Appeals Panel affirmed the trial judge’s decision.

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