07/16/2018
Defendants, in a consolidated case, appealed a decision of the trial judge sustaining a violation of G.L. 1956 § 31-15-12 (interval between vehicles). Defendants were part of a group of nine motorcyclists who were pulled over and cited for “following too closely.” Prior to Defendants’ trial, the court heard a separate trial regarding the same charge issued to the other motorcyclists. Those motorcyclists were found not guilty. On appeal, Defendants argued, among other things, that the State was barred from re-litigating issues under the doctrine of collateral estoppel. Collateral estoppel “‘prevents the relitigation of issue[s] actually litigated and determined between the same parties’ or those in privity with them.” Lee v. Rhode Island Council 94, 796 A.2d 1080, 1084 (R.I. 2002) (quoting Wilkinson v. The State Crime Laboratory Commission, 788 A.2d 1129, 1141 (R.I. 2002)). The Appeals Panel held that collateral estoppel did not apply because the issues were not identical and because the parties were not the same or in privity with one another. The Appeals Panel reasoned that, although the two trials revolved around the same charge, the issues differed because Defendants’ behavior “may have been different from their peers on the road that day.” Accordingly, the Appeals Panel affirmed the trial judge’s decision.
*Note: On October 16, 2018, the Appeals Panel amended the decision to remove footnote number 2.