RI District Court and Traffic Tribunal Case Law

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State of Rhode Island v. Zigmond Coffey, C.A. No. T12-0014 (May 4, 2012) Due Process

Defendant appealed from the decision of the hearing magistrate accepting his guilty plea to the charged violation of R.I.G.L. 1956 § 31-22-22 (safety belt use—child restraint) and imposing a sentence that included a six month license suspension.  Defendant argued that his guilty plea was not made knowingly, intelligently, and voluntarily.  The Panel explained that the Traffic Tribunal Rules of Procedure and the Rhode Island Supreme Court demand that all guilty pleas be made knowingly and voluntarily, and that the defendant bears the burden of demonstrating, with evidence, that a guilty plea was not made knowingly and voluntarily.  The Panel noted that the Defendant here was advised of the violation against him before entering his plea, and he chose to plead guilty.  Further, the Panel noted the Defendant did not produce any evidence to show that his plea was anything but voluntary.  Accordingly, the Panel sustained the charged violation. 

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