Places Where U-Turns Prohibited

Defendant appealed a decision of the trial judge sustaining a violation of G.L. 1956 § 31-16-4 (places where u-turns prohibited). Defendant argued that the trial judge’s decision was clearly erroneous because there was insufficient evidence to support a conviction. § 31-16-4 states that “no vehicle shall be turned so as to proceed in the opposite direction upon any curve or upon the approach to, or near the crest of a grade, where the vehicle cannot be seen by the driver of any other vehicle approaching from either direction within five hundred feet.” Here, there was testimony that Defendant made a three point turn in a construction zone, but the record did not contain any evidence showing that Defendant turned his vehicle while on a curve or near the crest of a grade. Furthermore, the record did not indicate that there were any vehicles approaching from either direction within five hundred feet. As such, the Appeals Panel held that there was insufficient evidence to support the conviction. Accordingly, the Appeals Panel reversed the decision of the trial judge and dismissed the charge.

State of Rhode Island v. Peter Turner, No. T16-0014 (August 6, 2018).pdf