RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Sara Smolenski, No. T16-0009 (January 24, 2018)

Defendant appealed a decision from the Trial Magistrate accepting Defendant’s plea to R.I. Gen. Laws 1956 § 31-47-9 (operating without insurance) and imposing a license suspension and fine. Defendant argued that the plea was not voluntarily and intelligently entered because the Trial Magistrate did not inform Defendant of the consequences that could result from her entering a guilty plea. The Appeals Panel, relying on the fact that Defendant’s license had previously been suspended for the same offense and that the arraignment judge had warned her of the sentence she was facing, found compliance with Rule 7(a) of the Traffic Tribunal Rules of Procedure, which requires that a plea be entered “voluntarily and with understanding of the nature of the charge and the judgment to be imposed.” Accordingly, Defendant’s appeal was denied and the Appeals Panel sustained the charges.

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