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State v. Lane

Citations: 4 Conn. Cir. Ct. 368; 232 A.2d 518; 1967 Conn. Cir. LEXIS 245Docket: File No. MV 10-37731

Court: Connecticut Appellate Court; March 31, 1967; Connecticut; State Appellate Court

Narrative Opinion Summary

In this case, the defendant appealed a conviction for speeding under General Statutes 14-219, challenging several court rulings related to evidence admissibility and the classification of the highway involved. The appeal centered on the admissibility of radar evidence, which lacked a proper foundation as the trooper had no personal knowledge of the radar's accuracy, violating the standards set by State v. Tomanelli. The court's classification of Route 2 as a non-limited access highway was pivotal, affecting the applicable speed limit and the defendant's legal arguments. The defendant's attempt to introduce counter-evidence, including photographs to demonstrate the highway's nature, was denied, infringing on procedural rights. The court's error in these rulings led to the judgment being set aside and a new trial ordered. The case highlights the importance of procedural fairness and the requisite foundation for admitting technological evidence in speeding violations.

Legal Issues Addressed

Admissibility of Radar Evidence

Application: The court ruled improperly by admitting radar evidence without a proper foundation or demonstration of its accuracy, as required by precedent.

Reasoning: According to State v. Tomanelli, proper foundation and demonstration of the radar's accuracy are vital for such evidence to be admissible.

Classification of Highways under Section 14-219

Application: The classification of Route 2 as a non-limited access highway was central to the defendant's conviction for speeding, impacting the applicable speed limits.

Reasoning: The key dispute was whether Route 2 was classified as a multiple-lane limited-access highway, as the defendant claimed, which could impact the legality of the speeding charge.

Prima Facie Evidence of Speeding

Application: The trooper's speedometer readings provided prima facie evidence of the defendant's speed, sufficient to establish a statutory violation.

Reasoning: The trooper's testimony, which included the speed recorded by his speedometer, was deemed prima facie evidence of the defendant's speed.

Right to Present Counter-Evidence

Application: The court erred by not allowing the defendant to present evidence countering the classification of the highway, violating procedural fairness.

Reasoning: The court's failure to allow this opportunity led to a denial of the defendant's rights.