State v. Robinson; State v. Palmer, Jr.; State v. Cabral; State v. Garden; State v. Barboza; State v. Furlano

Summary

The Rhode Island Supreme Court reviewed consolidated certiorari petitions arising from motorists' refusal-to-submit-to-chemical-test charges. The Court held that the District Court lacked subject-matter jurisdiction to hear the State's appeal from the Traffic Tribunal appeals panel because the governing statute authorized an appeal by an aggrieved "person," a term that did not include the State. The Court quashed the District Court's order and did not reach the merits concerning the statutory penalty and notice requirements.

Holdings

1. Section 31-41.1-9(a) did not confer subject-matter jurisdiction on the District Court to hear the State's appeal because the statute authorized an appeal by an aggrieved "person," and the statutory definition of person did not include the State.
2. Traffic Tribunal Rule 21(b) could not expand the District Court's subject-matter jurisdiction because procedural rulemaking authority cannot enlarge jurisdiction that the General Assembly did not confer by statute.

Questions Presented

1. Whether the District Court had subject-matter jurisdiction to hear the State's appeal from the Traffic Tribunal appeals panel under General Laws § 31-41.1-9(a).
2. Whether Traffic Tribunal Rule 21(b) could independently confer jurisdiction on the District Court to hear the State's appeal.

Disposition

quashed