RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Robert Braddock, C.A. T08-0073 (July 30, 2008)

The Defendant appealed the trial judge’s decision to sustain the charged violations of R.I.G.L. 1956 § 31-14-2 (speeding), R.I.G.L. 1956 §31-15-11 (laned roadway violation), and R.I.G.L. 1956 § 31-16-5 (failure to use a turn signal). The Defendant argued that the trial judge erred in sustaining the speeding charge because there was no evidence that the devices used to ascertain the Defendant’s speed were accurate and in good working order. The Panel noted that for speedometer or radar evidence to support a speeding charge, “the operational efficiency” of the device must be “tested within a reasonable time by appropriate method” pursuant to State v. Sprague, 322 A.2d 36 (R.I. 1974). The Panel held that because there was no evidence to establish the accuracy of the Trooper’s speedometer or radar, the trial judge erred in sustaining the charge. Accordingly, the Panel reversed the trial judge’s decision and dismissed the speeding charge.

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