Traffic Court Decisions admissible in Civil Trial

Admissability of Traffic Court Finding in a Civil Case.

1. If the defendant pleads guilty in traffic court, the guilty plea is admissible in a subsequent civil case. See Miller v. Hall, 161 Md. 111 (1931). It is admissible as an admission. See See Crane v. Dunn 382 Md. 83 (2004) for a full discussion

2. If the defendant simply paid the traffic ticket by mailing a check, that action (and the fact that a traffic citation was issued by the officer) is not admissible in a subsequent civil case. Briggeman v. Albert, 322 Md. 133 (1991). The action of mailing the check is equivalent to plea of “no contest,” which is also not admissible in a subsequent civil action. Paying a traffic ticket does not necessarily mean that the driver admits guilt; it may have been more costly for the driver to fight the ticket than to pay it.

3. If the defendant is tried in traffic court and is found guilty, the conviction is not admissible in a subsequent civil action. See Aetna Casualty & Surety Co. v. Kuhl , 296 Md. 446, 450 (1983); Brooks v. Daley, 185, 196 (1966). See also Eagan v. Calhoun, 347 Md. 72 (1997) (collecting cases). It is true that the standard of proof in traffic court is higher than that in a civil case. However, much less is at stake in traffic court. A defendant may not (and in most cases, would not) hire an attorney to fight a traffic ticket for, say, $75.00. Thus, it would not be fair to use the conviction against the defendant in a subsequent civil case in which he is being sued for say, $100,000. Also, there is no right to a jury trial in most traffic court cases. Traffic court procedures are also much more streamlined than Circuit Court procedures, and even District Court civil procedures ( i.e., no discovery).

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