RI District Court and Traffic Tribunal Case Law

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Seat Belt Use

District Court

District Court
11/10/2016
Jason Dellanoy v. State of Rhode Island, A.A. No. 16-26 (November 10, 2016)

Seat Belt Use

Defendant appealed the Appeals Panel’s decision sustaining the defendant’s violation of R.I.G.L. 1956 § 31-22-22(g) (“no seatbelt, operator”). Defendant argued that he could not wear a shoulder strap seatbelt because of a medical condition, so instead he wore a lap strap seatbelt. According to R.I.G.L. 1956 § 31-22-22(i), some individuals cannot, physically, wear a full safety belt and harness and, therefore, these individuals may be excused from wearing a full safety belt and harness. However, the operator must have a physician’s note stating that the operator cannot physically wear a full safety belt and harness. Since the defendant did not have this note, or at least did not present such evidence at trial, the District Court affirmed the Appeals Panel’s decision. 

Jason Dellanoy v. State of Rhode Island, A.A. No. 16-26 (November 10, 2016).pdf

District Court
03/25/2014
State of Rhode Island v. Jorge Rivera, A.A. No. 2013-127 Seat Belt Use

Seat Belt Use

Defendant appealed the decision of the Appeals Panel sustaining the violation of R.I.G.L. 1956 § 31-22-22(g) (no seat belt – operator). The District Court held that even if the operator had the waist strap fastened, he was still in violation of the statute because he did not have the requisite letter from a physician excusing him from wearing the shoulder strap for physical or medical reasons as the statute required. Accordingly, the Court affirmed the Appeals Panel.

State of Rhode Island v. Jorge Rivera, A.A. No. 2013 – 127 (March 25, 2014).pdf

Appeals Panel

Appeals Panel
07/16/2013
State of Rhode Island v. Jorge Rivera, C.A. No. T12-0082 (July 16, 2013)

Seat Belt Use

Defendant appealed the decision of the trial judge sustaining the violation of R.I.G.L. 1956 § 31-22-22(g) (Safety Belt use- Operator).  The Defendant argued that he did not have the shoulder strap portion of the belt across his chest because of a shoulder injury, but that he did have the waist portion of the belt properly buckled.  The Panel held that even if the operator had the waist strap fastened, he was still in violation of the statute because he did not have the requisite letter from a physician excusing him from wearing the shoulder strap for physical or medical reasons as the statute required. Accordingly, the Panel sustained the charged violation.

State of Rhode Island v. Jorge Rivera, C.A. No. T12-0082 (July 16, 2013).pdf

Appeals Panel
11/18/2009
M09-0025-Seat Belt Use

Seat Belt Use

Defendant appealed the decision of the Middletown Municipal Court sustaining the violation of R.I.G.L. 1956 § 31-22-22 (safety belt use). The Court agreed with the trial judge and held that § 31-22-22 only requires that there be a basis for a traffic stop other than a safety belt violation and that the defendant need not be charged with the “primary offense” in order to be charged with a seat belt violation. Thus, the Court affirmed the decision of the trial judge sustaining the charge against the defendant.

Town of Middletown v. John McNulty, C.A. No. M09-0025 (November 18, 2009).pdf