HomeMy WebLinkAbout02-5049 CivilDARYL STRICK,
Appellant
Vo
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
COMMONWEALTH OF
PENNSYLVANIA,
PENNSYLVANIA
DEPARTMENT OF
TRANSPORTATION,
BUREAU OF DRIVER
LICENSING,
Appellee NO. 02-5049 CIVIL TERM
IN RE: OPINION PURSUANT TO PA. R.A.P. 1925
OLER, J., February 13, 2003.
This license suspension appeal presents the issue of when an appeal must
be filed from imposition of an ignition interlock system requirement by the
Department of Transportation. Stated more precisely, the question is whether, in a
case where the motorist's criminal sentence did not include an ignition interlock
system requirement, an appeal must be filed within thirty days of the Department's
Official Notice of Suspension providing notice of (a) the motorist's suspension,
(b) the ignition interlock system prerequisite to restoration of driving privileges,
and (c) the thirty-day appeal period from the Department's action.
In this case, where the motorist filed an appeal from the Department's
action with respect to the ignition interlock system almost a year after the official
notice, the court granted a motion of the Department to quash the appeal as
untimely.~ From this quashal order, the motorist has appealed to the Pennsylvania
Commonwealth Court.2
In his statement of matters complained of on appeal, Appellant expresses
the issues on appeal as follows:
Order of Court, December 12, 2002. The order was entered on the docket by the prothonotary
on December 16, 2002.
1. [Appellant] appeals the quash of his appeal, as the
trial court erred when it was found that it was not timely filed.
2. Further, the trial court erred, because at the time
[Appellant] filed his request for an appeal, when
Commonwealth v. McManus, 2002 Pa. Super. 271 was still
good law and said Superior Court case, even if withdrawn,
was in full force and effect and mandated that the Court
consider the appeal as timely filed.
3. [Appellant] challenges the subject matter
jurisdiction of the Department of Transportation over him in
the above captioned matter where no Order of Court ever
existed mandating the Guardian interlock System apply to
[Appellant], and where the Department of Transportation is
taking or withholding his driver's license without any Order
3
of Court creating the statutory authority for it to do so.
This opinion in support of the order quashing Appellant's license
suspension appeal is written pursuant to Pennsylvania Rule of Appellate Procedure
1925(a).
PROCEDURAL HISTORY AND STATEMENT OF FACTS
As the result of an incident on March 4, 2001,4 Appellant Daryl Strick pled
guilty on September 4, 2001,5 in the Court of Common Pleas of Cumberland
County, to driving under the influence.6 The sentence for this third offense
overall7 did not include a requirement that he install ignition interlock systems on
his motor vehicles as a condition of restoration of his operating privileges.8
: Appellant's Notice of Appeal, filed January 15, 2003.
3
Appellant's Concise Statement of Matters Complained of on Appeal, filed January 27, 2003.
4 S~'¢ Commonwealth's Ex. 1, Hearing on Motion To Quash, December 11, 2002 (hereinafter
Com. Ex. ~ (driving record).
5 See Com. Ex. 1 (notice of suspension).
6 See Appellant's Ex. 1.
7 See Com. Ex. 1 (driving record).
8 Appellant's Ex. 1; see Act of June 22, 2000, P.L. 466, §l(b), 42 Pa. C.S. §7002(b) (2002)
(requirement that court order installation of ignition interlock device as condition for restoration
of operating privileges by department, in case of second or subsequent DUI conviction).
2
As a result of Appellant's conviction, Appellee Department of
Transportation mailed to Appellant an Official Notice of Suspension dated
October 30, 2001.9 This notice, which Appellant received shortly after its mailing
date,l° provided as follows, inter alia:
This is an Official Notice of the Suspension of your Driving
Privilege as authorized by Section 1532B of the Pennsylvania
Vehicle Code. As a result of your 09/04/2001 conviction of
violating Section 3731 of the Vehicle Code DRIVING
UNDER INFLUENCE on 03/04/2001:
Before PennDOT can restore your driving privilege, you must
follow the instructions in this letter for COMPLYING WITH
THIS SUSPENSION, PAYING THE RESTORATION FEE
and PROVIDING PROOF OF INSURANCE. You should
follow ALL instructions very carefully. Even if you have
served all the time on the suspension/revocation, we cannot
restore your driving privilege until all the requirements are
satisfied.
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.
In Commonwealth v. Mockaitis, 54 Pa. D. & C.4th 115 (Cumberland 2001), a challenge to the
constitutionality of the statutory ignition interlock system requirement was upheld in an opinion
authored by the Honorable Edgar B. Bayley of this court. The absence of a requirement in the
sentencing order for installation of such a system is attributable to this holding.
9 Com. Ex. 1 (Official Notice of Suspension).
l0 N.T. 6, Hearing, December 11, 2002 (hereinafter N.T. ~.
3
APPEAL
You have the right to appeal this action to the Court of
Common Pleas (Civil Division) within 30 days of the mail
date, OCTOBER 30, 2001, of this letter. If you file an appeal
in the County Court, the Court will give you a time-stamped
certified copy of the appeal. In order for your appeal to be
valid, you must send this time-stamped certified copy of the
appeal by certified mail to:
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg, PA 17104-2516~
Appellant did not appeal from the action of the Department represented by
this notice within thirty days of the notice.~2 About a year later, on October 17,
2002, Appellant filed an "Appeal from Suspension of Operator's Privilege,''~3
which is the subject of this opinion.
This appeal cited Appellant's receipt of a Restoration Requirements Letter
dated October 7, 2002, from the Department, noting various prerequisites to
restoration of his license, including payment of a restoration fee, proof of
insurance, and installation of the ignition interlock system on all of his vehicles. ~4
The appeal challenged in several respects the constitutionality of the statutory
ignition interlock system requirement,~5 and pointed out that the statute had been
declared unconstitutional by this county's court.~6 The appeal requested an order
~ Com. Ex. 1 (official notice of suspension).
~2 See N.T. 6-7.
~s Appellant's Appeal from Suspension of Operator's Privilege, filed October 17, 2002.
~4 Id. para. 2; Joint Ex. 2.
~5 Appellant's Appeal from Suspension of Operator's Privilege, filed October 17, 2002, paras. 6-
8.
16]d. para. 8; seeMockaitis, 54 Pa. D. & C.4th 115.
4
directing the Department to "issue [Appellant] a license forthwith, without any
special requirements.''~7
On October 29, 2002, the court issued a Rule upon the Department to show
cause why the relief requested by Appellant should not be granted.~8 In response
to the Rule, the Department filed a substantive answer to the appeal and also
moved to quash the appeal as untimely.~9 A hearing on the motion to quash was
held by the court on December 11, 2002.
Following the hearing, at which evidence was received and at which
counsel placed their respective arguments with respect to the motion on the record,
the court took the matter under advisement.2° On December 12, 2002, the court
issued the order from which Appellant has appealed to the Pennsylvania
Commonwealth Court, granting the Department's motion to quash the appeal as
untimely.21
DISCUSSION
Rationale for selection of Official Notice of Suspension as a££ea/ event.
The Official Notice of Suspension issued by the Pennsylvania Department of
Transportation derives from authority provided by the legislature in section
1532(b) of the Vehicle Code. Act of June 17, 1976, P.L. 162, §1, as amended, 75
Pa. C.S. § 1532(b) (2002). This notice is the functional equivalent of an order of a
~v Appellant's Appeal from Suspension of Operator's Privilege, filed October 17, 2002, para. 11.
~8 Order of Court, October 29, 2002.
19 Department of Transportation's Response to Rule To Show Cause, filed November 15, 2002.
:0 Order of Court, December 11, 2002.
:~ Order of Court, December 12, 2002. Because of the court's quashal on this ground, it was not
necessary to consider a second motion to quash, on other jurisdictional grounds, raised with
Appellant's consent by the Department at the hearing. See N.T. 7-13.
Following the court's quashal, Appellant filed a motion for reconsideration citing a subsequent
decision by another judge of this court which reached a result different from that which had been
arrived at in this case. See Heber/ig v. Commonwealth of Pennsylvania, Department of
Transportation, No. 02-4874 Civil Term (Ct. Com. Pls. Cumberland December 19, 2002)
(Bayley, J.). Reconsideration of the order was not granted, however, and Appellant filed a timely
appeal from the quashal.
5
government unit and is subject to a statutory right of appeal under the Vehicle
Code and under the Judicial Code within thirty days. Act of July 9, 1976, P.L.
586, §2, as amended, 42 Pa. C.S. §§5571-5572; Smith v. Commonrvealth
Department of Transportation, 749 A.2d 1065, 1066 (Pa. Commw. Ct. 2000); see
also Act of June 17, 1976, P.L. 162, §1, as amended, 75 Pa. C.S. §1550(a) (2002).
The importance to an orderly system of justice of a well-defined period
within which appeals must be taken from agency actions is emphasized by (a) the
rule that a right to appeal nunc pro tunc will be granted only in "extraordinary
circumstances," such as fraud or a breakdown in court operations, Smith, 749 A.2d
at 1066,22 and (b) the rule that the thirty-day appeal period is of jurisdictional
dimension, Henning v. Commonrvealth Department of Transportation, 687 A.2d
20, 21 (Pa. Commw. Ct. 1996); Heberlig v. Commonrvealth Department of
Transportation, No. 02-4874 Civil Term (Ct. Com. Pls. Cumberland December
19, 2002) (Bayley, J.); Grissinger v. Commonrvealth Department of
Transportation, No. 02-3842 Civil Term (Ct. Com. Pls. Cumberland October 24,
2002) (Bayley, J.).
Support for the position that the period for appeal in the present context
commences with the Department's Official Notice of Suspension is found in
appellate caselaw, established practice, and considerations of practicality. With
respect to caselaw, the Commonwealth Court has held that the ignition interlock
system requirement is an incident, or continuation, of suspension as opposed to a
mere condition of restoration, such as a restoration fee. Frederick v.
Commonrvealth Department of Transportation, 802 A.2d 701, 703 n. 1 (Pa.
Commw. Ct. 2002); Schneider v. Commonwealth Department of Transportation,
790 A.2d 363, 366 n.7 (Pa. Commw. Ct. 2002). The logical consequence of this
incidence is that an appeal under section 1550(b) of the Vehicle Code23 (pertaining
22 The present case does not involve an appeal nunc pro tunc. N.T. 7.
23 See Act of June 17, 1976, P.L. 162, §1, as amended, 75 Pa. C.S. §1550(a) (judicial review of
Department license suspensions, etc.)
6
to appeals from suspensions, revocations, etc., and subject to a thirty-day
timeliness requirement24) lies from the Department's initial notice of suspension
on a challenge to the ignition interlock system requirement. See Frederick, 802
A.2d at 702 (referring to such an appeal as "timely" and adjudicating motorist's
challenge to imposition of ignition interlock system requirement by Department).25
With respect to established practice, it appears that challenges to the
Department's action in connection with the ignition interlock system are almost
invariably being filed from the Department's Official Notice of Suspension,
notifying the motorist of the ignition interlock system requirement. See, e.g.,
Turner v. Commonwealth Department of Transportation, 805 A.2d 671 (Pa.
Commw. Ct. 2002); Frederick, 802 A.2d 702-03; Schneider, 790 A.2d at 365;
Garretson v. Commonwealth Department of Transportation, No. 02-3832 Civil
Term (Ct. Com. Pis. Cumberland December 5, 2002); Myers v. Commonwealth
Department of Transportation, No. 02-2018 Civil Term (Ct. Com. Pis.
Cumberland July 29, 2002); Stone v. Commonwealth Department of
Transportation, No. 02-1888 Civil Term (Ct. Com. Pis. Cumberland July 25,
2002); Adcock v. Commonwealth Department of Transportation, No. 02-1400
Civil Term (Ct. Com. Pis. Cumberland June 20, 2002); Ward v. Commonwealth
Department of Transportation, No. 01-3209 Civil Term (Ct. Com. Pis.
Cumberland June 12, 2002); Commonwealth Department of Transportation v.
Richardson, No. 01-6604 Civil Term (Ct. Com. Pis. Cumberland May 6, 2002)
(Hess, J.).
:4 "Appeals from Department of Transportation decisions suspending drivers licenses are granted
as of right by Section 1550 of the Vehicle Code .... Jurisdiction of such appeals lies in the courts
of common pleas as provided by Section 933 of the Judicial Code, . . . and an appeal must be
made there within thirty days .... "Henning v. Department of Transportation, Bureau of Driver
Licensing, 687 A.2d 20, 21 (Pa. Commw. Ct. 1996).
:5 Ironically, in Frederick, the Department had contended that the notice of suspension was not
the proper time to raise the ignition interlock system requirement issue, because it had not ripened
at that stage. Frederick, 802 A.2d at 702.
7
Finally, in view of the need to select one of several possibilities for an
appeal period in the present context, the most practical one seemed to the court to
be the one traditionally applicable to appeals from actions by the Department--the
official notice of suspension, containing notice, in addition to that of the basic
suspension, of the continuation of the suspension in the absence of installation of
ignition interlock systems in the motorist's vehicles and of the thirty-day appeal
period applicable to the Department's action. Other possible events for
commencement of the appeal period--such as the restoration letter, the date of
rejection by the Department of a request for restoration, and the initial date of the
continuation of suspension--did not, in the court's view, offer the advantages
inherent in familiar practice.
Effect of Commonrvealth v. McManus.
upon Commonwealth v. McManus, 2002
With respect to Appellant's reliance
PA Super 271 (Pa. Super. Ct.),
withdrawn, No. 479 WDA 2001 (Pa. Super. Ct. October 29, 2002) (per curiam), to
support the timeliness of his appeal, it is believed that the reliance is misplaced. In
McManus, the Superior Court affirmed a judgment of sentence on a direct appeal
challenging the constitutionality of the ignition interlock system requirement,
basing its decision primarily on the ground that the ignition interlock requirement
involved a civil consequence as opposed to an incident of sentence. In dictum, the
court opined that in any event an appeal from this aspect of the sentencing order
was interlocutory, stating that "[t]he ignition interlock order of [an] offender only
becomes ripe for review.., when [an] offender seeks restoration of his operating
privileges and it is denied by PennDOT because of his failure to comply with the
ignition interlock order... [or] when [an] offender does not apply for an ignition
interlock restricted license and his license suspension continues for an additional
year." Id. at ¶ 22. The opinion in McManus was with&awn by the Court on
October 29, 2002. McManus, No. 479 WDA 2001.
McManus is not, in this court's view, availing to Appellant in the present
case. First, the opinion has been withdrawn and lacks precedential value. Second,
8
the portion of the opinion supporting Appellant's position was dictum; had the
case been decided on the interlocutory issue, the result would have been a quashal
rather than an affirmance. Third, the opinion was not filed until about eight
months after Appellant's time to appeal from the official notice of suspension had
expired. Fourth, Appellant's appeal was not predicated upon either of the events
said in McManus to be a proper predicate for appeal--denial by the Department of
a request for restoration or continuation of a suspension in the absence of an
application for an ignition interlock restricted license--but was instead premised
upon receipt of a restoration requirements letter.
Subject matter jurisdiction of Department of Transportation. With respect
to Appellant's contention that the Department exceeded its authority in imposing
an ignition interlock systems requirement under the present circumstances, this
fact would not serve to relieve Appellant from the duty to file a timely appeal from
the Department's action. Shattuck v. Zoning Hearing Board, 93 Pa. Commw. 209,
217 n. ll, 501 A.2d 319, 323 n. ll (1985) (noting that, even though the "order may
have been an ultra vires action by the board, ... the landowner's failure to file a
timely appeal has taken that issue beyond this court's grasp"); see Commonwealth
Department of Transportation v. Messa, 158 Pa. Commw. 645, 648 n. 1, 632 A.2d
954, 955 n. 1 (1993) (holding that, even though the lower court's "jurisdictional
foundation [for the action] was vulnerable," the court lacked the ability to review
the action because an appeal was not timely filed); J.B. Steven, Inc. v. Department
of Transportation, 156 Pa. Commw. 360, 362-65, 627 A.2d 278, 279-81 (1993)
(holding that court lacked jurisdiction to review an action of the Department when
no timely appeal from the notice of the action was taken); see also Turner, 805
A.2d at 676 (stating that licensee who filed timely appeal in circumstances in
which the Department lacked authority to impose ignition interlock systems
requirement would be "relieved" of her existing obligation to comply with the
Department's action); cf Walker v. City of Birmingham, 388 U.S. 307, 87 S. Ct.
1824, 18 L. Ed. 2d 1210 (1967) (holding that a party may not defy a preliminary
9
injunction through process other than appeal regardless of apparent invalidity of
the injunction).
Many challenges to agency actions are premised upon a lack of authority,26
including cases in the present context challenging the Department's imposition of
an ignition interlock systems requirement in the absence of a court order. See, e.g.,
Turner, 805 A.2d 671; Schneider, 790 A.2d 363. To excuse a motorist from the
obligation to contest an action of the Department believed to be ultra vires by
means of a timely appeal would, in the court's view, invite chaos in the
administrative program pertaining to drivers and vehicles in the Commonwealth.
See Shattuck, 93 Pa. Commw. at 217 n. ll, 501 A.2d at 323 n. ll; see a/so Wa&er,
388 U.S. 307, 87 S. Ct. 1824, 18 L. Ed. 2d 1210 (stating that "respect for the
judicial process" mandates that individuals must pursue appeals from allegedly
invalid orders before disobeying those orders and cannot "ignore all the
procedures of the law" in disobeying an order before judicial invalidation).
For the foregoing reasons, the court entered the order now on appeal
quashing Appellant's license suspension appeal.
BY THE COURT,
J. Wesley Oler, Jr., J.
Karl E. Rominger, Esq.
155 South Hanover Street
Carlisle, PA 17013
Attorney for Appellant
26
See, e.g., Vernon Township Water Authority v. Vernon Township, 734 A.2d 935 (Pa. Commw.
Ct. 1999); In re Frederick F., 400 Pa. Super. 542, 583 A.2d 1248 (1990); Shattuck, 93 Pa.
Commw. 209, 501 A.2d 319.
10
Harold Cramer, Esq.
Elaine Blass, Esq.
Commonwealth of Pennsylvania
Department of Transportation
Third Floor, Riverfront Office Center
1101 South Front Street
Harrisburg, PA 17104-2516
Attorney for Appellee
11