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HomeMy WebLinkAbout02-3269JEFFREY S. VAN BOSKIRK Petitioner V. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. LICENSE SUSPENSION APPEAL (FROM IMPOSITION OF THE INTERLOCK REQUIREMENT AND THE IMPOSITION OF AN ADDITIONAL YEAR OF SUSPENSION FOR FAILURE TO COMPLY) LICENSE SIJSPENSlON APPEAl AND NOW, comes Pelitioner, Jeffrey S. Van Boskirk, by and through his attorneys, Mancke Wagner & Tully, and makes the following averments in support of this License Suspension Appeal: 1. Petitioner, Jeffrey S. Van Boskirk, is a Pennsylvania licensed driver with a residence address of 15 N. Fifth Street, Lemoyne, Cumberland County, Pennsylvania, 17043. 2. Respondent, Pennsylvania Department of Transportation, Bureau of Driver Licensing, has a mailing address at Riverfront Office Center, Third Floor, 1101 South Front Street, Harrisburg, Dauphin County, Pennsylvania 17104-2516. 3. Petitioner received a notice of license suspension by way of letter dated July 1, 2002 from the Department of Transportation indicating, in pertinent part, "Before your driving p#vilege can be restored you are required by law to have all vehicle(s) owned by you to be equipped with an Ignition Interlock System. This is a result of your conviction for D#ving Under the Influence. If you fail to comply with this requirement, your dwing p#v~lege v~ll remain suspended for an edditional year. You will receive more information regarding this requirement approximale~y 30 days before your eligibility date." Said notice is attached hereto as Exhibit and incorporated herein by reference. 4. The apove-mentioned provision, as part of the Deparlment's notice of July 1, 2002, is illegal, invalid, and improper for reasons which include, but are not limited to, the following: (a) At the time of Petitioner's sentencing in Cumberland County, the tdal cou.rt did not order that each motor vehic e owned by the Petitioner be equipped with an approved ignition interlock system and PennDOT has no authority to order the ignition interlock or to extend the license suspension for an additional year. See Schneider v. PennDOT, 790 A.2d 363 (Pa.Cmwith. 2002). (b) (c) The provisions of Act 63 of 2000 are unconstitutional in that the Act violates Article III, {}1 of the Pennsylvania Constitution which provides, Jn perlinent part: "no/aw shall be passed except by Bill and no Bi//shall be so altered or amended on its passage through either House as to change its odginalpurpose.' Const. Art. III, {}1. The provisions of Act 63 violate the Pennsylvania Constitution because no Bill shall be passed containing more than one subject by including provisions for restitution for identity theft along with ignition interlock requirements. Const. Art. III, {}3. (d) The provisions of Act 63 are unconstitutional in that it violates Article III, {}4 of the Pennsylvania Constitution which provides, in pertinent part: "E ' very Bill shall be considered on three different days in each House" Const. Art. III, ~. '" (e) The provisions of Act 63 violate Petitioner's equal protection and due process rights under the State and Federal Constitutions by treating similarly situated persons differently without a rational basis. Said unequal enforcement of the law is not rationally related to the protection of the public from intoxicated drivers. The provisions of Act 63 violate the Separation of Powers Doctrine and procedural due process as the interlock requirement is not analogous to the imposition of costs in a criminal proceeding, is not administrative in nature and interferes with the sentencing power of the court as it requires the court to cerlify to the executive branch (PennDOT) whether 2 the ignition interlock systems have been installed before PennDOT will .reinstate the operating privilege which necessarily requires the court to investigate whelher or not the devices have been installed without procedural due process. See Commonwealth v. Mockaiti.~, 54 D&C 4~h 155 (Cumb. 2001). (g) The provisions of Act 63 violate due process because PennDOT has no authority or jurisdiction over vehicles owned by a motorist but not registered and not operated on a public highway. (h) The provisions of Act 63 violate due process because the statute is vague in failing to define ownership and is overbroad because, by its reach, it punishes constitutionally protected activity, i.e. ownership of a non-registered vehicle maintained and/or used solely on private property in violation of Pefitioner's rights under Article, I, {}9 of the Pennsylvania Constitution and the 5*h Amendment of the Unites States Constitution. (i) PennDOT has waived any perceived authorization to have the ignition interlock requirements and/or extend the license suspension by its failure to file an appeal, within 30 days of notice of the court's failure to impose such requirements on the Petitioner. 5. Petitioner requests the court take judicial notice of Senate Bill 849 and all of its prior forms prior to becoming Act 63 of 2000 including the legislative summary obtained from the Pennsylvania State website, www. legis.state.pa.us, in chronological order beginning with the summary and printer numbers 952, 1225, 1814, 1918, 2038, and 2059. WHEREFORE, Petitioner prays that this Court declare that the portion of the Department's notice of July 1, 2002 which reads: "Before your driving privilege can be restored you are required by law to have all vehicle(s) owned by you to be equipped with an Ignition Interlock System. This is a result of your conviction for Driving Under the Influence. If you fail to comply with this requirement, your driving privilege will remain 3 suspendedforanaddiffonalyear. Youwillreceivemoreinforma#onregardingthisrequirementapproximately 30 days before your eligibil~ date" be declared illegal, unconstitutional, and sthcken as part of the Department's notice and direct that the Department reinstate the Petitioner's driving privileges after the one (1) year suspension for the conviction for driving under the influence, subject to the payment of the restoration fee and providing proof of insurance. Dated: Respect~y~ John B. Ma~cke, Esq., ID No. 07212 Mancke, V~agner & Tully 2233 N. Front Street, Harrisburg, PA 17110 717-234-7051, Attorney for Petitioner 4 VERIFICATION I hereby vedfy that the statements made in this document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. Date/7~ ~-~p' ~ ~Oskir~. ~,/,/,~~ 5 CONNONHEALTH OF PENNSYLVANIA DEPARTHENT OF TRAHSPORTAT[ON Bureeu of Driver Licensing Nail Datez JULY 01, 2002 J£FFR[Y $ $$ N FZFTH LEflOYN£ PA IRZVER LZCENS£ · lATE OF BZRTH LZCENSE ZN BUREAU Dear HR. VANBOSKZHK: This is an O~f~C~e~ Not'ce Of the 9uePcnc~on of your Driving Privilege as authorized by Section 1552B of the PennsYlvania Vehicle Code. As a result of your 04/23/2002 conviction of vtoZsting Section $75! of the Vehicle Code DRZVZNG UNDER [NFLUENCE on ~a/o&/2eel~ Your driving PriviZege is SUSPENDED for · period of Z YEAR(B) effective 0&/1~/2002 at 12:01 a.m. HARNZNG: Zf YOU ire convicted of driving uh~le Your license is suspended/revoked the Penalties ~il! be a MIN;HUN of 90 days iePrieonment AND · 1,OEO fine AND your driving privilege Nil! be susPended/revoked for lefare PsnnDOT can restore Your driving privilege, You suet fallou tho instructions in th~s Zetter for COHPLYZNG H~TH TH~S SUSPENSION, PAYZNG THE RESTORATION FEE and PROVIDING PROOF OF INSURANCE, You Ihouid fOZ2ON ALL inetruet~ene Very eare~u~iy. Even Xf YOU have Ic~ved a2! thc t~mm off the gr~v~iege unt~Z 022 the requirements are eat~ef~ed. ~o/z~xz~z ~:Z~ /1//318974 ARTHUR ~LIRRA¥' STUDIO PAGE 0217561'1221293S PRZSON RELEASE REDUZREMENT (ACT]S1) The Court of CUHIERLAND CTY, 2002 has sentenced You violation. Pursuant to Code, you vi1! not suspsnsion/rivocatton Court Nuiber 162~ Court Teri to serve a prison term for this Section 15~1(a.i) of the Vehicle receive credit for this or any additional suSPension/revocation until YOu coIplete Your pr/son term. The Court must certify your completion to PenflDOT. You may wish to contact your probation officsr and/or the Court -Afb_er .3LD~L~ r~l)_~U ~-make sure that PennDOT Ss p~perZ¥ not/f/ed. COURT ORDER TREATMENT PROGRAH (ACT 122) Pursuant to Section 15qB(d) of the Vehicle Cede, the Court of CUMBERLAND CTY , Court Number 1&2~ Court Term 20~2 has ordered you to attend a treatment program for slcohoZ or drug odd/ct/on. As a result of the court order, this susPension/revocation shall remain in effect unti! the Department ts notified by the above Court that YOu have successfully completed treatment and you are otherwise ellglbZe for restoration of your driving ;rivtlege. PAYZN; THE ~ESTORATXON PEr You must Pay p restoration fee to PennDOT to be restored from a suspension/revocation of Your drtvtng priviZege. To Pay your restoration fee, COlOlete the following steps: 1. Roturn the enclosed APPZlcation for Restoration. The amount due is 1/sted on the a~oltcation. 2. ~r/te Yoor driver's license number (~istsd on the first Dogs) on ~ne ~h~ck or money credit. Follov the Payment and mailing of the application. order to 'offseT1-P~O121r ............... ~nstructions on the back [GNZTZQN ZNTEELOC~ Before Your dr/v/nD Privilege can be rIitOred You are required by Zaw to have 811 vehiclsCs) ovoid by You to be equipped with an Zgn/tlon Znterlock SYStem. This ~s a result of Your conviction for Driving Under the Znfluence. Zf you fall to comely vith this requirement, your driving Privilege ~i1! remain suspended for an additional year. You ~i1! receive lore Information regarding this requirement approximately 30 deys before your s~igib~ty date. 02175&112212955 PROVZD[NG PROOF DF ZNSURAN;E Within the last ]0 days of Your suspension/revocation, we will send you a /after asking that You prow/de Drool of insurance at that t/me. This letter w111 list acceptable documents and what will be needed /f you do not own a web/elm registerod /n PennsyXvan/a. zeoortant= Please make sure that PoflnDGT ls notified if You move from your current address. You may not/fy PonnDOT of your address change by calling any of the phone numbers You have the right to appeal this action ta the Court of Common Pleas (Civil D/v/sion) with/n $0 days of the date, JULY 01, 2002, of this letter. Z~ you flle mn in the County Cpupt, the CouPt wtlZ glve YOU m ~ePtlf~ld o~y o~· the .PpelI, ~n order for your appeal to be vii/d, You must send this time-stamped certified copy of the appeal by certified mail Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Rivarfront Office Center Harrisburg, PA 1710~-251& Remember, th/s Le an O~;Z¢ZAL NO?ZCR OF RU~PENSZON. Sincerely, Rebecca L, Blckley, D/rector Bureau of Driver L/censing ZNFORRATZON 7:00 a,e. to 9~00 p.m. ~N STATE 1-800-Y&Z-4&00 TOD ;N STATE OUT-OF-STATE 717-391-6190 TOD OUT-OF-STATE HEB SZTE ADDRESS www.dot.state.pa.us 1-800-228-0676 717-391-6191 JEFFREY S. VAN BOSKIRK Petitioner COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING Respondent · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA : LICENSE SUSPENSION APPEAL (FROM : IMPOSITION OF THE INTERLOCK : REQUIREMENT AND THE IMPOSITION OF : AN ADDITIONAL YEAR OF SUSPENSION : FOR FAILURE TO COMPLY) AND NOW, this/I ~ day of_~, 2002, upon Petition of Jeffrey S. Van Boskirk, a heating is set on the License Suspension Appeal for the ?-~'~' day of ('~)~~ ,2002 at C~; 0~) ,3, .m. in Courtroom No. /'7/' , Cumberland County Courthouse, One Courthouse Square, Carlisle, Cumberland County, Pennsylvania. Notice of said hearing shall be given by Petitioner's counsel to the Department of Transportation at least sixty (60) days pdor to the date of said hearing· Distribution: Pmthonotary's Office Office of Chief Counsel, PennDOT 1101 S. Front St., Harrisburg, PA 17104-2516 John B. Mancke, Esquire 2233 N. Front St., Harrisburg, PA 17110 BY THE COURT: JEFFREY S. VAN BOSKIRK, APPELLANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : V. : COMMONWEALTH OF : PENNSYLVANIA, DEPARTMENT : OF TRANSPORTATION, : APPELLEE : CIVIL ACTION - LAW 02-3269 CIVIL TERM IN RE: TRANSCRIPT OF PROC~mnINGS Proceedings held before the HONORABLE KEVIN A. HESS, J., Cumberland County Courthouse, Carlisle, Pennsylvania, on Monday, October 7, 2002~ in Courtroom Number Four. APPEARANCES: P. Richard Wagner, Esquire For the Appellant George Kabusk, Esquire For the Appellee 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: MR. WAGNER: MR. KABUSK: THE COURT: MR. KABUSK: Good morning. Good morning, Judge. Good morning, Your Honor. Mr. Kabusk. This is the case of Jeffrey S. Van Boskirk versus Commonwealth of Pennsylvania, Department of Transportation, case number 02-3269. This is an appeal from a Notice of Suspension dated July 1st, 2002, which notified the petitioner, Jeffrey S. Van Boskirk, operator's number 18287041, that as a result of his 4.302 conviction of violating Section 3731 of the Vehicle Code, Driving Under the Influence of 10/6/01, his driving privilege was suspended for a period of one year. Additionally, that notice informed him of the requirement for the Ignition Interlock, and that Official Notice of Suspension is Subexhibit Number 1 in the Department's packet of documents. Subexhibit 2 is a Report of Clerk of Court of Cumberland County convicted 4/23/02, seal attached to the original. Subexhibit 3 is Acknowledgment of Suspension, and Subexhibit Number 4 is driving record which appears in the file of the Defendant, Jeffrey S. Van Boskirk, operator's number 18287041, date of birth 9/12/58, in the Bureau of Driver Licensing, Harrisburg, Pennsylvania. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 The Departments documents are under seal and certification. I've provided a copy to Mr. Wagner, and I move for the admission of what's been marked as Commonwealth Exhibit Number 1. THE COURT: objection? MR. WAGNER: THE COURT: MR. KABUSK: case, Your Honor. THE COURT: Ail right. Is there any There's no objection. Okay. And that is the Department,s Very well. Anything you want to offer by way of testimony for the record? MR. WAGNER: if it please the Court. THE COURT: MR. WAGNER: No. I just have one exhibit, Okay. If it please the Court, I'm Rich Wagner, and I'm appearing for Mr. Mancke, and I have marked as Defendant's Exhibit Number 1 a certified copy of the Order of Court dated the llth day of June, 2002, a decision by Judge Oler, the sentencing of Judge Oler in which the issue of the interlock is not required, consistent with Exhibit Number 2 of PennDOT, the DL-21. We would offer that. I've provided a copy to the Department of Transportation, and we would move for the admission of that document. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: MR. KABUSK: THE COURT: MR. WAGNER: I assume there's no objection. No objection, Your Honor. Very well. And with that we believe the decision in this case is controlled currently by Schneider, and we would rest. THE COURT: And just so that I'm absolutely clear about this, he is still in the initial suspension for DUI, right? And you're seeking to strike the language that says before it's restored he must comply? MR. WAGNER: restored by the Department. this juncture. THE COURT: MR. WAGNER: No. He has his license back, We're satisfied with that at Oh, okay. The Department takes the position, I believe, that upon the filing of this notice of appeal, that that acts as an automatic restoration of his driving privilege, notwithstanding the conviction. Therefore, he has his driving privilege returned, and we're comfortable with that, and we're not seeking to have any change in that position that PennDOT now takes. THE COURT: clear about that. Okay. MR. WAGNER: Okay. I just wanted to be Thank you. Thank you, Judge. (Whereupon, the proceedings concluded at 9:09 a.m.) CERTIFICATIO_________~N I hereby certify that the proceedings are contained fully and accurately in the notes taken by me on the above cause, and that this is a correct transcript of same. Official Court Reporter The foregoing record of the proceedings on the hearing of the within matter is hereby approved and directed to be filed. Date Kev' i/ A. Hess, J. Judicial District JEFFREY S. VAN BOSKIRK, : Appellant : ; VS. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, Appellee AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02-3269 CIVIL IN RE: LICENSE SUSPENSION APPEAL ORDER /¥' day of November, 2002, the appeal of Jeffrey S. Van Boskirk is SUSTAINED but only to the extent that the requirement that all vehicles owned by him must he equipped with an ignition interlock system prior to the restoration of his driving privileges is STRICKEN. See Albert John Schneider v. Com. of Pa., Dept. of Trans., Bureau of Driver Licensing, No. 1513 C.D. 2001 (Pa. Cmmwth. 2002). BY THE COURT, A. Hess, J. P. Richard Wagner, Esquire For the Appellant George Kabusk, Esquire For PennDOT :tim JEFFREY S. VAN BOSKIRK, : Appellant : VS. : .' COMMONWEALTH OF : PENNSYLVANIA, DEPARTMENT: OF TRANSPORTATION, : Appellee : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02-3269 CIVIL 1N RE: APPEAL ORDER AND NOW, December 3, 2002, in accordance with Rule 192,5 of the Rules of Appellate Procedure, the Pennsylvania Department of Transportation having filed a notice of appeal, it is directed to file of record, within fourteen (14) days hereof and serve upon the undersigned a concise statement of the matters complained of on the appeal. P. Richard Wagner, Esquire For the Appellant Terrance M. Edwards, Esquire For PennDOT :rim BY THE COURT, Ke~. Hess, J. /-- JEFFREY S. VAN BOSKIRK, Appellant VS. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT: OF TRANSPORTATION, · Appellee · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02-3269 CIVIL IN RE: APPEAL PURSUANT TO RULE 1925 In this case, the petitioner, Jeffrey Van Boskirk, appealed from a notice of driver's license suspension which he received from the Department of Transportation and which was dated July 1, 2002. He appealed, specifically, from that portion of the notice which read as follows: Ignition Interlock Before your driving privilege can be restored you are required by law to have all vehicle(s) owned by you to be equipped with an Ignition Interlock System. This is a result of your conviction for Driving Under the Influence. If you fail to comply with this requirement, your driving privilege will remain suspended for an additional year. You will receive more information regarding this requirement approximately 30 days before, your eligibility date. On November 14, 2002, this court sustained Mr. Boskirk"s appeal to the extent that the above requirement, namely that all vehicles owned by him must 'be equipped with an ignition interlock system prior to the restoration of his driving privileges, was stricken. The Department of Transportation has appealed from our order. On December 3, 2002, we filed an order directing that the Department of Transportation file, within fourteen days, a concise statement of the matters complained of on appeal. This was not done. Arguably, all issues have now been P. Richard Wagner, Esquire For the Appellant George Kabusk, Esquire For PennDOT waived. See Com. v. Lord, 553 Pa. 415, 719 A.2d 306 (1998). We will not, however, presume upon that matter. Our order of November 14, 2002, was entered in accordance with Albert Schneider v. Com. of Pa., Dept. of Transp., Bureau of Driver Licensing, 790 A.2d 353 (Pa. Cmwlth. 2002). In that case, the Commonwealth Court was presented with the same situation that pertains in the matter sub judice. Namely, though the sentencing court failed to impose an ignition interlock requirement, PennDOT has sought to impose the requirement absent a court order. In Schneider, the court held expressly that PennDOT has no unilateral authority to impose ignition interlock device requirements if the trial court fails to do so. It was because of this express holding that we entered our order of November 14, 2002. January 10, 2003 :rim