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riecide the issue of whether, at the tilne of SUllivan's license
suspension, PennDOT had the authority to suspend a driver's license
based on an out'of'state conviction pursuant to the Driver. License
Compact of 1961 (Compact).
Because we conclude that, at the
relevant time, the Commonwealth had not enacted the Compact into
law, we affirm the Or:der of the Commonwealth Court,
El\CTUAL lIND PROCEDURAl. HISTORY
The Compact is a contractual agreement among states intended
to pr:omote compliance with each party state's dr:iving laws and
regulations.
Besides Pennsylvania, the Compact has thirty-nine
party jurisdictions (thirty-eight states and the District of
Columbia), each of which has enacted the Compact into law by
statute. J
(,. ,continued)
or an adjUdication of delinquency based on section 3731 or 3733. .
~ Ala. Code 55 32.6.30 to 36; Ari;:, Rev. Stat, 55
28.160l to 1605: Ark. Code 55 27'l7.l01 to 106: Cal, Veh. Code 5
l5000 at seg,; Colo. Rev, Stat, 55 24-60-110l to ll07: 1992 Conn.
Acts 92.186 (Reg. Sess.); Del. Code tit. 21,5 8l01; D,C,Code 55
40.1501 and l502; 23 F1a, Stat, Ann. 55 322,43 to 322.48; Haw, Rev.
Stat. 55 286C.1 and 286C-2; Idaho Code 55 49-2001 to 2003; Ill,
Ann, Stat. ch. 625, ~ 5/6.700 to 708; Ind. Code Ann, 55 9-28-1'1 to
6; Iowa Code 55 321C.1 and 321C,2; Kan. Stat, Ann. 55 8-1212 to
12l8; La. Rev. Stat. Ann, 55 32:1420 to 1425; Me. Rev, Stac. tit.
29, 55 631 to 675; Md, Transp, Code 55 16-701 to 708: Minn. Stat,
Ii 5 171. 50 to 56; Mi s s, Code Ann, 95 63 - 1 - 101 to 113; Ho. Ann. S ta t ,
55 301.600 to 302,605; Mont, Code Ann, 59 61-5-401 to 406; 2A Neb.
Rev, Stat, App, at 840; Nev. Rev, Stat. 55 483,640 to 483,690; N,H,
Rev, Stat, 5 263.77; N.J. Stat. Ann. 55 39:50-1 to 14; N.M. Stat,
Ann, 5566-5-49 to 5l; N.Y, Veh. & Traf, l.aw 5516; N,C, Gen. Stat,
li5 20-4,21 to 4,30; Ohio Rev. Code Ann, 5 4507.60 Okla. Stat. tit,
47, 55 781 to 788; Or. Rev. Stat. !i 802,540; S,C. Code Ann, 55
56.1.610 to 690; Utah Code Ann. 5~ 41-2-501 to 506; Vt. Stat. Ann,
(continued,. ,)
(J-158-1997] . 2
he did argue that PennDOT improperly failed to notify Sullivan that
the suspension of his license was based on the Compact. The trial
cou~t sustained Sullivan's appeal, and PennDO'l' appealed to the
Commonwealth Cour:t,
The Commonweal th coun considered Anicle VII I of the Compact,
which provides as followsl
(l) This compact shall enter into force and become
effective as to any state when it has enacted the same
into law.
(2) Any party stat~ may withdraw from this compact by
enacting a statute repealing the same. . .
The court concluded that the Conunonwealth had not "enacted [the
Compact) into law" as r:equired by Article VIII (l), and, ther:efore,
PennDOT lacked the authority to suspend Sullivan's license based on
his conviction in Nebraska.
/ll.S.CUSSION
On appeal to this Court, PennDOT first argues that the
Commonwealth Court sh'Juld not have addr:essed the issue of whether
the Conunonwealth enacted the Compact into law, because Sullivan did
not raise it in the trial court. In the first instance, PennDO'l'
overlooks the fact that, until the September 20. 1995 hearing, it
had not notified Sullivan that it was relying on the Compact for
authority to suspend his license, Moreover, the general rule that
issues not r:aised in the lower court may not be raised on appeal
applies only to appellan ts, not to appellee:>. Ssl.e Conunonwealth v.
K~, 540 I?a, 416, 658 A.2d 345 (1995) (plurality opinion);
[.J'158-1997J - 5
~:d.QQsl v, Ell/art, 383 Pa, 110, ll7 A,2d 899 (1955).
lis an
appellee, Sullivan was not precluded from r:aising in the
Commonweal th Court the issue of whether: the Compact had been
enacted into law,'
PennDOT next argues that the Commonwealth did enact the
Compact into law pur:suant to Section 6146 of th~ Vehicle Code, 75
Pa,C.S. ~ 6146, which pr:ovides as follows:
The secr:etary may enter into agr:eements r:elating to the
enfor:cement of this title, including, but not limited to:
(l) the Driver l,icense Compact and any other
agreements to notify any state of violations
incurred by residents of that state. .
According to PennDOT, the Secretary's exercising the authority
conferred upon him by 75 Pa.C,S, ~ 6146(1) is sufficient to
constitute enactment of the Compact into law.5
We regretfully
disagree.
In its brief, PennDOT makes reference to Pa,R,/I,P. 1551,
which governs the scope of review of quasijudicial orders, Rule
1551 provides, in part, that, "[nJo qucsti.on shall be heard or
considered by the court which was not raised before the gover:nment
unit except: (l) Questions inVOlving the validity of a statute. .
" Although the question of whether the Commonwealth enacted the
Compact into law involves the effect of Section 6146 of the Vehicle
Code, 75 Pa.C.S, ~ 6146, that statute's validity is not at issue,
Accordingly, Rule l55l(a) (1) is inapplicable.
Pursuant to Section 6152 of the Vehicle Code, 75 Pa.e.S.
~ 6152, agreements entered into by the Secretary must be published
in compliance with Part II of Title 45, In the Commonwealth Court,
Sullivan argued that PennDOT's published notice failed to comply
with those requirements, in that the notice contained only a
synopsis of the Compact and not the full text. However, because we
conclude that enactment of the Compact into law requires the
passage of a statutl~ by the LegiSlature, we do not address the
adequacy of the published notice.
[J-158 -1997J - 6
The Compact is a contract between states, Accordingly, we are
bound to interpret its ter:ms according to their plain medning,
.5m1, e...s4, Stl!!uart-Y...J1cChesnev, /198 Pa, 45, 444 A.2d 659 (1982),
Fur:thermore, this Court will not rewrite the terms of a contract,
nor give them a meaning that conflicts with that of the language
used, .I.d.." at 50-51, 444 A.2d at 662 (quoting Robert F. Felte..
Inc. v. White, 451 Pa, 137, 144, 302 A,2d 347, 351 (l973) (quoting
Haaartv v. Wi..ll.iaJJL..hk.eui, Jr. Co.. Inc" 342 Pa. 236, 239, 20 l\.2d
317, 319 (1941))). Pursuant to Ar:ticle VIII (1) of the compact, its
provisions "enter into force and become effective as to any state
when it has enacted the [Compact] into law," In the context of law
making, the plain meaning of the term "enactment" is "(t]he method
or pr:ocess by which a bill in the Legislature becomes a law,"
BL/lCK'S LAW DrCTION/lRY 526 (6th ed, 1990),
The language of Article VIII(2) of the compact supports this
interpretation, It provides that, "[alny party state may withdr:aw
from this compact by enacting a statute repealing the same,. "
If the passage of a statute were not also required for entry into
the compact, the withdrawal provision of Article VIII(2) would be
incongruously burdensome, We cannot conclude that the Compact's
drafters intended such a disparity between entry into and
withdrawal from the Compact, nor are we empowered to give the terms
of the contract a meaning inconsistent with the drafters' clear
intent, .s..e.e, fLJL" Steuart, 498 Pa, at 48.49, 444 A.2d at 66l;
Felte, 451 Pa. at 143-44, 302 l\,2d at 351, Thus, we hold that the
[J'158-1997! . 7
Compact bacomeo effective as to the Conunonwealth only when the
Legislature passes a statuto adopting it, Any other construction
would impermissibly strain th~ language of the contract beyond its
plain meaning.
Notwithstanding the Compact's expr:esa language, PennDOT argues
that, in passing Section 61~6 of the Vehicle Code, 75 Pa,C,S, 9
6146, the Legislatur:e proper:ly df.!ll~gatod to the Secr:etary of
Transportation (Secretary) the authority to enter into the Compact.
Overall, the Legislature may delegate policy making authority to an
administrative agency, so long aa the Legislature makes the "basic
policy ci10ices" and establIshes "adequate standards which will
guide and restrain the exercise of the delegated administrative
fllOctions." Gilliaan v.~nsvlvania Horse Racing Conunission, ~92
Pa. 92, 96, 422 A,2d ~87, 489 (1980) {citing IiLlliam Penn Parking
~araae, Inc. v, Citv of Pitts!lur.!Jb, 464 Pa. 168, 346 A,2d 269
(1975); Chartiers Va11ev Joint Schools v, Countv Board of Scho~
Directors of Alleaheny County, 418 Pa, 520, 211 A,2d 487 (1965);
Be10vskv v. Redevelooment Authoritv of the City of Phi1adelohia,
357 Pa. 329, 5~ A,2d 277 (1947)).
Here, PennDOT asserts tha t
Section 61~1 of the Vehicle Code, 75 Pa,C.S. 5 6141, evinces the
Legislature's basic policy choice to participate tn interstate
agreements regarding the regulation of drivers,' and that Section
Section 6141 of the Vehicle Code, entitled "Declaration
of policy", provides thatl
It is the policy of this Conunonwealth to promote and
(continued" ,)
I,) . 1 'i 8 - 199 '/ ] - 8
Compact becomes effective as to the Commonwealth only when the
Legislature passes a statute adoptinq it. Any other: constr:uctlon
would impermissibly strain the lanquage of the contract beyond its
plain meaning,
Notwithstanding the Compact's express language, PennDOT argucs
Lhat, in passinq Section 6146 of the Vehicle Code, 75 Pa.C,S, ~
6146, the Leg islature properly delegatcd to the Secretary of
Transportation (Secr:etar:y) the authority to enter: into the Compact.
Over:all, the Legislature may delegate policy making author:ity to an
administrative agency, so long as the Legislature make,s the "basic
policy choices" ilnd establishes "adequate standards which will
guide and restrain the exercise of the delegated administrative
functions," Gilliaan v, PennsYlvania Horse Racing comml ssion, 492
Pa. 92, 96. 422 A.2d 487, 489 (1980) (citin') lii.U.i.am Penn parkina
~..a..g"e...o-....IILC-.....-CLo. City oL Pittsburgh, 464 Pa, 168, 346 A.2d 269
(1975) I Chartiers Valley .JoJ.n.!;;...lichools v. County Board of School
Directors o~ Alleahenv County, 418 Pa. 520, 211 A.2d 487 (1965) I
Belovsky v, RpdeveloDment Authoritv of the City of Philadelnhia,
357 Pa. 329, 54 A,2d 277 (1947)),
Here, PennDOT asserts that
Section 6141 of the Vehicle Code, 75 Pa,C.S, ~ 614l, evinces the
Leqislature' 5 basic policy choice to participate in interstate
agreements regarding the regulation of drivers,' and that Section
, Section 6141 of the Vehicle Code, entitled "Declaration
of pOlicy", provides that:
It is the policy of this Commonwealth to pr:omote and
(continued", )
(J-158-19971 - 8
In Ruch v. Wilhelm, 352 I'a, 586, 43 A.2d 894 (1945), this
Court held that the power of "substantive enactment" is vested in
the Legislature alone, Thus, the Court deter:mined that,
"[a)uthor:lty may be given to a government official or: an
administrative agency to make rules and regulations to cover.' mere
maUet's of detail for the impleml!ntation of 01 statute, but where
the statute itsolf is lacking in essential substantive provisions
the law does not permit a transfer of the power to supply them, for
the leqis~ature cannot delegate its power to make a law." ~, at
592-93,43 A,2d at 897.
In this case, We view 75 Pa,C,S. Ii 6146(1) mer:ely as a
delegation of author:ity to implement the mechanics of the Compact
in the Commonwealth, pur:suant to the Constitution's separation of
power:s, however, the Legislature could not delegate to the
Secretary the power to enact the Compact into law as r:equired by
its terms, Thus, while not unconstitutional, 75 Pa.C.S, Ii 6146(1)
is insufficient to render the Compact effective as to the
Commonwealth.
Indeed, the LegiSlature seemed to concede as much in passing
Act No. 1996 .l4 9 (Act) Al though the Secretary had purported to
enter into the Compact effective January 1, 1995, on December 10,
1996, the Leqis~atur:e passed the Act, which, ilUJll: A.U.a, added
Section 1581 to the Vehicle Code. That section sets forth the full
text of the Compact and provides that, "[tJ he Driver's License
[J-158 '1:)97) - 10
as mandated by 75 Pa. C.S, 51532 (b) (3).
At the statutor:y appeal hearing, DOTasser:ted its
authority to suspend Rulli van's license based on the Nebraska
conviction under the Dr:iver Licens$ Compact (Compact), effective
January 1, 1995, pur:suant to notice published in 24 Pa, Bull. 5609,
According to DOT, the Compact a\Jthor:izes the home state to give
effect to the out-of-state conduct as provided by the laws of the
home state, DOT then moved to admit a copy of the Nebraska
conviction report,
Counsel for Sullivan objected to admission of the repor:t
as inadmissible hearsay because the document was not pr:operly
cer.titied as required by 42 Pa. C.S. 55329(a). In addition,
counsel for Sullivan asserted the following: 1)' the notice
purported to suspend the license under 75 Pa. C,S, S1532(b) for
violation of 75 Pa. C.S, 53731, and Sullivan did not violate that
section; 2) for the notice to be valid, it must set forth the
authority under which DOT is proceeding; and 3) DOT had no
authority to suspend Sullivan'S license under the Vehicle Code or
under the Driver License Compact, which has not been enacted into
law in the Commonwealth.
Common Pleas sustained Sullivan's appeal. The court
tound that DOT's notice was deficient in that it failed to set
forth the authority upon which DOT based the suspension, and it
found that the Nebraska conviction report WaSilot properl.y
certified. DOT appealed.
Our review of a common pleas decision in a motorist'.
2
statutory appeal from suspension of his or her operating privilege
is limited to deter:mining whether necessary findings of fact were
supported by competent evidence of record and whether the trial
cour:t cOl1ll11itted error:s of law or abused its discr:etion.
Commonwealth v, Dan!Q..r..th, 530 Pa, 327, 608 A,2d 1044 (1992).
Before this Court, DOT asserts 1) that the notice was sufficiently
infornativfl to apprise Sullivan of the factual and statutory basis
for the suspension and to provide him with the opportunity to
adequately prepare a defense, and 2) that DOT's certification of
the Nebraska conviction report was admissible as a DOT document
pursuant to 75 Pa, C,S, S1550(d).
DOT defends the adequacy of its notice of suspension on
due process grounds, but the issue is not precisely framed in terms
of due process. In substance, Sullivan's objection and the basis
for his statutory appeal, is that DOT had no authority to suspend
Sullivan's license for the Nebraska conviction either under 75 Pa,
C,S, S1532(b), as stated in the notice, or under any other law of
the Commonwealth, At the statutory hearing, when DOT first
revealed that it was pr:oceeding under the Driver License Compact
(Notes of Testimony at p. 2.), Sullivan il1ll11ediately asserted DOT's
lack of authority to have entered into an interstate compact and
its lack of authority to proceed under the Compact, (Notes of
Testimony at p. 4.)
We now consider whether DOT has the authority (or
jurisdiction) to suspend a driver's license based on an out-of-
state conviction pursuant to the Compact, The power and authority
3
to bEl exercised by administrative agendes must be .ither expr.ssly
conferred or given by necessary implication by the logislature,
DeDar:tment ot EnviI~ntal ReAQur.~4S v. ~tl.r_~~unty HU8hrQQ;
[ADa, 499 Pa, 509, 454 A,2d 1 (1982),
Accor:ding to DOT, thQ General Assembly, in 75 Pa. C,S,
56146, specitioallY author:ized the Secretary ot Tran~portation to
enter into the Compllct on the Commonwea 1 th' s behalf, 'I'hat section,
in pertinent par:t, per:mits the secretary to
enter into agreements relating to .~torcument
ot thie tit~e, inCluding, but not limited tOI
(1) the Dr i ver: License compact and any
other agr:eements to notity any stllte ot
violations incurr:ed by residents ot that
state I
(2) agr:eemonts to Buspend or revoke the
oper:at ing prl. v 110ge of Ponn5Y 1 von ia licensed
dr:iver:s who are convicted in foderal court or
in another stllte of l'lny oUenae essontially
similar to thORO enumer:ated in section 1532(a)
and (b) (relating to rovocation or: suspension
ot operating privilege) I
75 Pa, C,S, 56146, "Allagreoments, arran'iJemente and declarations,
and amendments thor:eto, shall be in writing and shall be published
in compliance with Part II ot Title 45 (rolating to publication and
ettectiveness ot Commonwealth documents), The department shall
provide copies tor public distrl.bu1:ion upon nquest, II 75 Pa. C.S.
56152,
Although 75 Pa. C,S, 56146 doss speoitically mention the
Compact in its grant ot author i ty to enter into entorcement
agreements, that authority is insutticient to give the Compact the
ettect ot law, A state can delegate to an administrative agency
the authority to enter into an interstate compact, but a state may
4
join a compact only in the manner specified in the compact,
Par:ticipation in the Driver License compact is only by
enactment, Ar:ticle VIII of the Compact pr:ovides, "(1) This compact
shall enter into force and become effective as to any state when it
has enacted the same into law(,]" and "( 2) (a] ny par:ty state may
withdraw from this conlpact by enactin9 a statute repealing the
sam.",," The Driver License Compact: Administrative Procedures
Manual 4-5, U,S, Dep't of Transp, (1990), A history, published as
Appendix E of the Administrative Procedures Manual, characterizes
the Compact as "(a]n inter:state compact
" ,
a formal and
contractual agreement between two or mor:e states, '" enacted into
state law in each par:ticipatin9 jurisdiction, usually with
identical wordin9' " IlL. at 37, Participation in the Compact must
be effected by enactment, and the Compact, by its own ,terms, is not
effective until it is enacted into law.2
2 Enactment is "(tJhe method or process by which a bill in the
Le9islature becomes a law." Black's Law Dictionary 472, (5th ed,
1979), All participatin9 states have enacted the Compact into law:
Ala, Code 5532-6-30 - 32-6-36 (1975)1 Ariz. Rev. stat. 5528-1601 -
28-1605, Ark. Code 5527-17-101 - 27-17-106; Cal. Veh. Code 515000
et seq. (West); Col". Rev. stat. 5524-60-1101 - 24-60-1107; 1992
Conn, Acts 92-186 (Re9' Sess.); Del. Code tit. 21, 58101; D.C. Code
5540-1501, 40-1502 (1981); 23 Fla. stat, Ann. 55322.43-322.48
(West); Haw. Rev. stat. 55286C-l, 286C-2; Idaho Code 5549-2001 -
49-2003; Ill, Ann. Stat. ch. 625, para. 5/6-700 - 5/6-708 (Smith-
Hurd); Ind, Code Ann. 559-28-1-1 - 9-28-1-6 (West) 1 Iowa Code
55321C.l, 321C.2; Kan. Stat. Ann, 558-1212 - 8-1218; La. Rev. stat.
Ann. 5532:1420-32:1425; Me. Rev. Stat. tit. 29, 55631-675; Md,
Tr:ansp. Code 5516-701 - 16-708; Minn. Stat. 55171.50-171,56; Miss.
Code Ann. 5563-1-101 - 63-1-113 (1972); MO. Ann. stat. 55301.600-
302.605 (Vernon); Mont, Code Ann. 5561-5-401 -61-5-406; 2A, Neb.
Rev. stat, app. at 840 (Reissue 1985); Nev. Rev, Stat. 55483.640-
483.690; N.H. Rev. Stat 5263.77; N.J. Stat, Ann. 5539:50-1 - 39:50-
14 (West); N.M, Stat. Ann. 5566-5-49 - 66-5-51 (MiChie 1978); N,Y.
Veh, & Traf. Law 5516 (McKinney 1989); N,C. Gen. Stat. 5520-4,21 _
20-4.30; Ohio Rev, Code Ann. 54507.60 (Baldwin); Okla, Stat, tit,
5
In contrast, Flo~ida's Nonresidsnt Violator Compact, 23
Fla, stat. Ann, 55322.49-322,50, which tolloWB the Florida Driver
License compact in the Flor:ida statutes, provide. tor par:ticipation
by resolution,
Ar:tich VII ot Florlda'. Nonresident Violator
Compact states that entry into the compact is mad. by resolution ot
ratification, executed by authori zed ort ic id. ot the applying
jurisdiction, and including a citation ot the authority by which
the jurisdiction i. empowerod to become a party to the compact, 23
Fla. stat, Ann, 5322.50, It the Driver License Compact provided
tor such a procedure, other than enactment, the authorization in 75
Pa. C.S. 56146 would be sutficient to permit DOT to join the
~ompact by agreement, how~ver, it does not,
The Commonwealth'. nttumpt to participate in the Compact
wi thout enactment threa tons the Compact'. ertecti venen in other
state., Oecisione trom juri.dictions where the Compact has been
enacted illustrate the kind ot pr:oblem. that can arise when the
Compact has not be.n enacted in the reporting state, In peocle v.
Siems, 523 N,!,2d 727 (Ill. ^pp, ct, 1988), an Illinois appeals
court retused to uphold a license llIuspension based on a Kentucky
conviction becauee Kentucky had not enacted the Compact, In
McKenzie v. Reaht.I.Ax, No, 9!l-01-005, 1996 Ohio App. LEXIS 854
(Ohio Ct. App, Mar, 5, 1996) (per curiam), the court reached the
47, 55781-788/ Or. Rev, Stat, 5802,540/ S,C. Code Ann. 5556-1-610 -
56-1-690 (Law, co-op. 1976)/ Utah Code Ann. 5541-2-501 - 41-2-506
(1953)/ Vt, Stat. Ann, tit, 23, 553901-3910; Va, Code 5546.2-483 -
46.2-488 (1950) / Wuh, Rev. Code Ann. 5546,21.010-46,21.040 (West) /
W. Va. Code 55178-1A-1, 178-1A-2 (1986); Wyo. Stat. 5531-7-201, 31-
7-202 (1977).
6
~ame conclusiQn, again based on KentuckY not having enacted the
compact. In Division of Motor Vell~l.es v. KleiMtl, 486 A.2d 1J24
(N,J, Super, ct. App. oiv. 1985), the court r:eached a contrary
concl.usion, upholding a suspension based on a Vermont conviction
even though Vermont was not a member state, but only because
another New Jersey statute, other than the compact, authorized
suspension based on an out-of-state conviction,
The Compact's language requiring enactment is consistent
with the Commonwealth's established legal principles. Article III
of the Compact would have the effect of making an out-of-state
traffic offense punishable within the commonwealth, ~ at J, in
contravention of the well-settled rule that only the legislature
has the power to detine criminal offenses and to determine the
punishment to be imposed.l
Not only has the Compact not been enacted in the
commonwealth, DOT has not complied with the pr:ocedures required to
give effect to reciprocal agreements authorized by 75 Pa, C,S,
56146, DOT has failed to publish the compact in compliance with
Part II of Title 45, as specified in 75 Pa. C.S. 56152, 00'1'
published a notice of its membership in the Compact with a
synopsis, 24 Pa. Bull, 5609 (1994), The full text of the Compact
has never appe~red in the Pennsylvania Bulletin or in the
Pennsylvania Code; therefore, DOT is not entitled to tho statutory
3 Section 107 of the Crimes Code, 18 Pa. C.S. 5107. In
pertinent part, "(bl COIllllOD law orime. abolbbed.-- No conduct
constitutes a crime unless it is a crime under this title or
another statute of this Commonwealth." 18 Pa, C,S. 5107(b).
7
presumption ot 45 Pa. C,S. 5905 that the document was duly
promulgated and that all applicable regulations were tollowed.4
w. are dismayed wi th DOT's lack ot candor during all
phases ot this litigation, In its notice to sullivan, DOT made no
mention ot the Compact as the basis tor the license suspension;
Sullivan made his appeal knowing that his Nebraska trattic
violation was not a viohtion ot 75 Pa, C,S, 51!532(b), At the
statutory hearing, DOT announc.d that it waB proceeding under the
Compact, citing to the Pennsylvania Bulletin. DOT's briet to this
Court quotes ) iberally t~om the Compact.
At no time was the
Compact made part ot the recor:d in this case, even though the
Compact is not published and is available to the public only
through DOT, In weighing tho mer:its ot the arguments, the Court is
entitled to review the Compact in its entirety, not just those
provJ,sions that DOT deems pertinent.
Because the Compact itselt requires that it be enacted
into law by the legislatures ot all the participating states and
because the Commonwealth has never enacted the Compact, DOT is
without authority to proceed under the Compact to suspend the
operator's license ot any Commonwealth resident based on an out-of-
state conviction tor any tr:attic ottense, At the present time, DOT
may not suspend an operator's license based on an out-ot-state
4 45 Pa. C.S. 5905 provides that publication ot a document in
the code or the bulletin creates a rebuttable presumption that the
document was duly issued or promulgated, approved as to legality,
and all requirements othe~wise met. Even it DOT were entitled to
the presumption, our conclusion that the Compact is invalid unless
enacted ettectively rebuts this presumption.
S
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSI)(mTATION
(WHn: OF C'IIIU'I'OI'NSt:1.
,"WICI,I: & 'I!lAHK l.AW 1lI\'ISION
IUn:llHIOI'iT OFHn: n:NTt:II
1101 SIlUTlIl'lION'r SHIEH
IIAllIUSlIUIIG, rl:NNS\'l. \' ANI,\ 17104.1514
(717) 787.1H.\0
l'AX, (717) 705.1111
September 16, 1996
Judge George E, !'!oITer
Court of Co 111m on Pleas of Cumberland COUnly
Courthouse, I Courthouse Square
Carlisle, PA 17013
.]1..0'/
REI Samuel Larry Reed, Jr, v Comlllw. or I'a" Dept. or Transportation, No. 96.306lt Civil Term
Dear Judge Hoffer:
Enclosed please Ilnd a MOlion for Continuance in the above mentioned malter, TIle malter is
scheduled for hearing September 23, 1996. and the Department is respectfully requesting a cOnlinuance, I
contacted Mr, Hershey, Esquire, auomey lor the mOlorist. and he does nOI object to the continuance. For
your convenience, ! hllve prepared II proposed Order,
Sincerely,
. J
t\A../{C"-?-
Georg/H, Kabusk
Assistant Counsel
GK/gk
Enclosures (3)
Cc:
David E. Hershey, Esquire, 2233 North Front Street. Harrisburg, PA 17110
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(11) yuur P~llllun~r '~I1e1ng p~null1ed 0 oee<llld llm~ fllr uClluno fur whlcl1 he hud
I)r~vluuhly h~en penull1ed ond/ur woo llcqulll~d Ill' churl!~h,
(c) lIullc~ III lh~ puhllc I. eOlltPined In the Pennhylvunlu llull~tiu Vul. 24, Nu, 4~,
Nuv, ~, I'I'J4, p, ~()I)'I, Indkpted Ihpt unly dlUr~~h Ill' "drunk driving" ore
r~dprocul ond lh~ chorge. ol!oin.t the dd~lIdunl did n'.,1 cUII.lltut~ drunk
drlvllll!.,
(d) nllllncullllll III Ih~ puhlle Cllncernlng reciprllclly Uh wdl a. the Priv~r Ueen5f1
CumpucI uud Admlni.trollve Procedure. Mauuul, d~urly IndlcPte that driving
a mlltllr vehicle while under the influence I. IImil~d III Ihn.c churgco which
op~ciflcully ar~ "driving a motor vehicl~ whll~ lInd~r Ihe influenc~ uf alcohllllc
h~verul!~' Ilr u nurcotic 10 a degr~~ which r~nder' Ihe driver Incupahl~ Ill' ,afdy
drivilll!. n IllOlor vehicle" of which cunduct lhe defendunl Wllh nut I!ullty,
(e) th~ 1)~nl1hylvania Bullelln, U6 well uo thc Driver licen.e Cum pact and
Adminlhlrallve Procedure~ Manual, clearly Indicale, Ihul Ihe IIcenhlnl! authorily
ill the home hlate .hall give 'ouch effecl to th~ conducl "' Is provided hy the law,
of lh~ hllllle statc' and under the lawo uf th~ hllllle 'llll~ your Petllillner would
h~ ARD eliglhle,
(f) Ihe Driver Ucen~e Compacl I~ nul helng enforc~d lu Pennsylvania excepl f',r a
f~w vllllullonh and said enforcement therefore d~nl~. equal prlltectlon and due
proce," and has resulted In Illegal delegation of aUlh"rity and vlolallon of law,
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961508940000504
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Sineertl\l,
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RtbteeB L. Bickle~, Dirtetor
8ureBu of Driver Licensing
SEND FEE/LICENSE/OL-16LC/TDI
OePBrtment of TrBnsportBtion
BureBu of Orivtr Licensing
P.O. Box 68693
Harrisburg, PA 17106-8693
INFORMATION (7100 AM TO 6130 PM)
Pittsburgh Area - 412-565-5670
Philadelphia Area - 215-698-8100
Harrisburg Area - 717-787-3130
Toll Free 1- 800-932-4600
T.O.O. 1- 800-228-0676
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WI DO HI"C"V C~"T1" THAT
THI WITHIN I A T.UI AND C'"
~lHe:l::~TH. ORIGINAL
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MANCKE. WAGNER. HERSHEY & TUll vJU: :' 1 j996 [if .
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SAMUEL LARRY REED. JR,
PETITIONER
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY.
PENNSYLVANIA
lJ6.3064
v.
DEPARTMENT OF TRANSPORTATION. :
BUREAU OF DRIVER LICENSING
RESPONDENT
LICENSE SUSPENSION APPEAL
MOTION !'OR CONTINUANCE
The Commonweahh of Pennsylvania. Department ofTransportlltion, Bureau of Driver
Licensing (Dep~.rtment). by and through its attorney, George H. Kabusk. Esquire, respectfully
represents a~ follows:
I. The Department mailed to Samuel Larry Reed, Jr.. a notice intimning him that as a
result of the Department of Transportation (Deparllnent) receiving notification from Maryland of
his conviction on March 25. 1996. of driving unrler the influence on July 3. 1995. which is the
equivalent to Section 3731 of the pennsyl vania Vehicle Code, his driving privilege was being
suspended for one year as mandated by Section 1532B of the Vehicle Code.
2. Mr. Reed tiled an appeal of the above mentioned suspension.
3. A hearing in the matter is schcduled for September 23, 1996,at 10:30 a.m. in
Courtroom Number 3.
4. The suspension which is the subject of this appeal is based on the Driver License
Compact (Compact).
('Olll/l/(I/III'l!allll '1(1'I!III1,I)'/I'<III/a. f)1!f!a,."lIt'l/l (1/7;"1II,ll/oI'lal/01/, IllIl'l'l/Il '!I'f)I'/VI!I' Uet'lIs/l/l(,
682 A.2d 5 (I'll, Cmwlth, 1996).
5. Thc suspcnsion which is thc subject ufthisappcal is bascd unthc Drivcr's Liccnsc
Compact.
6. Thc Communwcalth Court on July 29, 1<)96, in SlIfl/vallv. ('Oll/lI/OIlWt'(IIIII 0/
Pel/I/.lylvall/a, f)ef!al'/Il/e/ll O/7;"III.ljJOl'I(II/01/. BIII'I!(/f/ '!I'DI'/wI' Un'IIs/lIg, 682 A.2d 5 (I'll.
Cmwlth, 1996) hcld thatthc Dcpartmcnt did not hllvc lIuthority to suspcnd I) driver'sliccnsc
ba~ed onlln out-of-statc conviction pUrSUal1l10 thc Driver's Liccnsc Compact bccausc it had not
been propcrly cnactcd intu law.
7. Thc Suprcme COUl1acccptcd f!el/l/olI./iJI' aI/oCt/IIII' filcd by thc Dcpartmcnt.
8. The Suprcmc Cuurt affinncd thc ordcr uf thc Cummonwcalth Court in SIII//vall v,
COllllllomveallh o/Pellllsylval//l/. Def!l/rtllll!/II of Trall.\11O/'Ial/cm. BIII'el/1I o./DI'/vf!/' Llcells/lIg,
No. 0023 W.O. Appeal Docket 19<)7, in an opinion issued on Fcbrullry 26, 1998.
9. The Departmcnt had no authority 10 slIspcnd the motorist's operating privilege in this
matter because the Commonwcalth had not propcrly enacted thc Driver's Licensc Compact at the
time when the Departmel1ltook this action.
J O. Thc Commonwealth cnactcd into law the Drivcr's License Compact by Section 10 of
Act of 1996, Dec. 10, P.L. 925, No. 149, cffcctivc December 10, 1996, at 75 Pa. C.S. 1581-1585.
II. The enactment ofthc Driver's Liccnsc Compact has no cffect on this suspension
whi~h was based upon the Driuer's License Compact bcfore it was enacted. See MOl'eland v.
Deparllllelll 0./ Trallsportal/oll, 70 I A.2d 294 (Pa. Cwmth. 1997).
12. The motorist's opcrating privilcgc has bccn rcstorcd pending appcal pursuant to
Section 1550 of the Vehiclc Codc.