RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Neal Gaudreau, A.A. No. 06-04 Probable Cause

Defendant appealed the decision of the Appeals Panel sustaining the violation of R.I.G.L. § 31-27-2.1 (refusal to submit to a chemical test). The Court held the results of the horizontal gaze nystagmus (HGN) field sobriety test are admissible for probable cause purposes. Furthermore, where the defendant failed field sobriety tests of physical dexterity as well as the HGN, probable cause for arrest existed. Accordingly, the Court affirmed the decision of the trial court sustaining the charge against the defendant.

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