RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Zachary Flanders, A.A. No. 03-134 Anonymous Tips

The state appealed the decision of the Appeals Panel dismissing the violations of R.I.G.L. 1956 § 31-27-2.1 (refusal to submit) and R.I.G.L. 1956 § 3-8-9 (transportation of an alcoholic beverage by a minor). The state claimed that the Appeals Panel’s decision to suppress the officer’s testimony that a group of children informed him that the defendant had a gun, because it amounted to an anonymous tip, was in error. Here, the District Court held that the Appeals Panel erred in holding that the information provided to the officer amounted to an anonymous tip because the officer knew who was providing the information, and had also observed the informants interact with the defendant. Therefore, based on the totality of the circumstances, the officer knew whether the informants were capable of providing reliable information. However, the Court went on to hold that the trial judge’s suppression was harmless error and sustained the dismissal of the violations against the defendant.

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