HomeMy WebLinkAbout93-0358 Civil (2)PENNSYLVANIA STATE IN THE COURT OF COMMON PLEAS OF
POLICE, BUREAU OF CUMBERLAND COUNTY, PENNSYLVANIA
LIQUOR CONTROL
ENFORCEMENT,
Appellee
V. CIVIL ACTION - LAW
CAN, INC.,
Appellant 358 CIVIL 1993
IN RE: APPEAL FROM LIQUOR LICENSE SUSPENSION
BEFORE OLER, J.
ORDER OF COURT
AND NOW, this 714 day of July, 1993, upon careful consideration of
Appellant's Appeal from a liquor license suspension and fine imposed by the
Pennsylvania Liquor Control Board, as well as the briefs submitted upon the matter,
and after review of the record from the proceedings below, Appellant's Appeal is
DISMISSED and the decision of the Board is AFFIRMED.
BY THE COURT,
Wesley Oler, Jr. J.
Thomas M. Ballaron, Esq.
Attorney for Appellee
Stephen J. Dzuranin, Esq.
Attorney for Appellant
:rc
PENNSYLVANIA STATE IN THE COURT OF COMMON PLEAS OF
POLICE, BUREAU OF CUMBERLAND COUNTY, PENNSYLVANIA
LIQUOR CONTROL
ENFORCEMENT,
Appellee
V. CIVIL ACTION - LAW
CAN, INC.,
Appellant 358 CIVIL 1993
IN RE APPEAL FROM LIQUOR LICENSE SUSPENSION
BEFORE OLER. J.
OPINION AND ORDER OF COURT
Oler, J.
This case is presently before the Court on an appeal from a Pennsylvania
Liquor Control Board (PLCB) decision imposing a $1000 fine upon Can, Inc.
(Appellant) and a suspension of Appellant's liquor license for a period of 120 days.'
For the reasons set forth in the following Opinion, the decision of the PLCB will be
affirmed.
As previously determined by this Court, "our scope of review will be limited to
an examination of the existing record to determine whether the findings below are
supported by substantial evidence, whether there was an error of law committed, and
whether there was an abuse of discretion."' Based upon this standard, the facts
contained in the record certified by the PLCB may be summarized as follows:
1 See Pennsylvania State Police, Bureau of Liquor Control Enforcement v. Can, Inc., Case
No. 92-0295, Opinion of Pennsylvania Liquor Control Board.
2 Opinion of Court, March 2, 1993, at 3-4.
358 CIVIL 1993
In October, 1990, Pennsylvania State Trooper Diane Stackhouse initiated an
investigation of Can,
Inc., trading as Johnnie's Cafe at
201
Enola Road, East
Pennsboro Township,
Cumberland County, Pennsylvania.'
At
this time, Trooper
Stackhouse "frequented Johnnie's Cafe several times a week, ... just ... to get a feel for
the place [and to be] seen as a regular patron.t4
Subsequently, beginning on November 8, 1990,$ and continuing until August
27, 1991,8 Trooper Stackhouse was involved in approximately thirty drug transactions
either in or on the licensed premises.' At least seven of these transactions involved
employees of Appellant while they were either working or off duty.'
In addition to being involved in drug transactions with the patrons and
employees of Johnnie's Cafe, Trooper Stackhouse also observed several instances of
unusual behavior which led her to believe that drug activity was occurring on the
premises. This behavior included frequent entering and leaving of the bathrooms by
3 Hearing Before Administrative Law Judges of the Pennsylvania Liquor Control Board,
May 20, 1992, at 85 (hereinafter N.T. _).
4 N.T. 86.
6 N.T. 86.
6 N.T. 151.
' N.T. 86-151. The Opinion of the Administrative Law Judges makes specific findings as
to when the transactions occurred on the licensed premises and the parties involved in these
transactions.
8 See Opinion of Administrative Law Judges, Findings of Fact 13, 33-35, 37, 42-43.
old
358 CIVIL 1993
the patrons and employees,9 an "unusual amount of phone calls both with the pay
phone and the phone underneath the bar,"10 frequent entering and exiting of the bar
by certain individuals,11 and smoking of marijuana cigarettes or bowls along the side
of or in the parking lot of the building. 12 Furthermore, Trooper Stackhouse
overheard conversations regarding drug activity "typically every time on every date
that [she] went" into the licensed premises."
Trooper Stackhouse also testified as to the extensive involvement in drug
activities of several employees of Appellant. Such testimony included Trooper
Stackhouse's observations that a certain employee of Appellant,14 "would give [her]
information concerning who was dealing inside the bar,i15 and that she would give
Trooper Stackhouse information regarding drug activity in and around the
premises.18 Additionally, Trooper Stackhouse testified as to the reputation of a cook
9
N.T. 117.
10
N.T. 118.
11
N.T. 118.
12
N.T. 118.
13
N.T. 119.
14
N.T. 135-43.
15
N.T. 139.
16
N.T. 140.
3
358 CIVIL 1993
at the licensed premises, 17 stating that his "main purpose other than a cook was the
runner to get drugs.i18 In this regard, she explained that "[y]ou would give him the
money, and he would go get [the drugs] and come back in and bring [the drugs] into
the bar or make a deal that you could go outside the parking lot and make that
deal." 19
Additionally, Trooper Stackhouse gave testimony as to the presence on the
premises of Ronald P. Nott, the owner and president of Can, Inc., 20 on a frequent
basis. Trooper Stackhouse stated that during the course of her one-year investigation
of the licensed premises, she observed Ronald P. Nott "[alt least 50 or more times" in
the licensed premises.21 During this time, Ronald P. Nott "was around the bar, in the
dining room, [and] in the kitchen,"22 and "[h]e was there when [Trooper Stackhouse]
was there."23
In addition to the testimony presented by Trooper Stackhouse, Ronald P. Nott
also testified before the Administrative Law Judges. Mr. Nott stated that the first
17
N.T. 159-60.
is
N.T. 160.
is
N.T. 160.
20
N.T. 61.
21
N.T. 161.
22
N.T. 162.
23
N.T. 161.
4
358 CIVIL 1993
time he became aware of the trafficking and use of drugs on the licensed premises was
when the arrests were made on November 7, 199124 Moreover, Mr. Nott testified
that the employees who were arrested for drug activities were no longer employed by
Appellant." Furthermore, Mr. Nott also indicated that if he perceives any drug
activity occurring on the licensed premises, he requests the individuals involved in
such activity to leave the premises immediately.e
There was also testimony presented before the Administrative Law Judges that,
on January 22, 1992, David Khali, a liquor control enforcement officer for the
Pennsylvania State Police, Bureau of Liquor Control Enforcement '21 mailed two
Notice of Violation letters to Appellant, one by first class mail and the other by
certified mail.28 The letter sent by certified mail was erroneously received by
Christine Zimmerman, 29 the president, secretary and treasurer of the Playground
24 N.T. 243.
25 N.T. 243.
' N.T. 244. Additional testimony was also presented by employees and patrons of
Johnnie's Cafe indicating that, subsequent to the arrests of November 7, 1991, Appellant has
had a drug-free policy and has instituted patrols of the restrooms in the bar. See N.T. 206-40.
27 N.T. 32.
' N.T. 34. Although Appellant never received either of the two letters, counsel agrees
that the address on the letters was correct. N.T. 31.
29 N.T. 43-44.
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358 CIVIL 1993
Lounge." The letter sent by regular first class mail, although correctly
addressed to Appellant, was never received by Mr. Nott.31 Rather, this letter was also
received by Christine Zimmerman. However, However, Appellant did receive the citation from
the Bureau of Liquor Control Enforcement on February 15, 1992.33
Following the hearing, the Administrative Law Judges ordered Appellant to pay
a fine of $1000 and suspended Appellant's Restaurant liquor license for a period of 120
days.34 Appellant appealed this order to the PLCB, which dismissed the appeal and
affirmed the decision of the Administrative Law Judges.35
Appellant has presently filed an appeal to this Court, contending that it was
first notified of the violations when it received the citation on February 15, 1992, and
since this was more than thirty days after the completion of the Bureau of Liquor
Control Enforcement's investigation, Section 4-471 of the Liquor Code" prevents the
30 N.T. 43.
3' N.T. 62-63.
32 N.T. 44-46.
33 N.T. 66.
34 Opinion of Administrative Law Judges, at 14.
' Opinion of the PLCB, at 7.
' Act of June 3, 1971, P.L. 143, §1, as reenacted and amended, 47 P.S. 4-471 (1993
Supp.).
N
358 CIVIL 1993
imposition of a penalty for the violations.s' Furthermore, Appellant contends that
thore
"[n]o facts were presented to sustain the finding that Appellant should have known of
such activity on the licensed premises until receipt of the citation,"saand, therefore,
"[t]he effect of the findings below is to [impermissibly] hold [Appellant] strictly liable
for non -liquor code violations .1131 Finally, Appellant contends that "[t]he decisions
below failed to afford proper weight to evidence presented that [Appellant] took
substantial affirmative action to try to prevent illegal drug activity on the licensed
u41
premises,i40 and, as such, those decisions were "arbitrary and capricious.
Section 4-471 of the Liquor Code states that "[n]o penalty provided by this
section shall be imposed for any violations provided for in this act unless the bureau
notifies the licensee of its nature within thirty days of the completion of the
investigation. 1141 "The purpose of this provision is to give warning to the licensee that
his activities have been under investigation and that his license is about to be
endangered." Commonwealth of Pennsylvania, Liquor Control Board v. Greenspan, 438
" Appellant's Appeal, paragraphs 20-21.
' Appellant's Appeal, paragraph 23.
' Appellant's Appeal, paragraph 24.
4' Appellant's Appeal, paragraph 25.
41 Appellant's Appeal, paragraph 26.
' Act of June 3, 1971, P.L. 143, §1, as reenacted and amended, 47 P.S. 4-471(b) (1993
Supp.).
7
358 CIVIL 1993
Pa. 129, 132, 264 A.2d 690, 691 (1970).
In reference to the fulfillment of this notice requirement, the courts of
Pennsylvania have held that "Section 4-471(b) does not require actual notice" to be
sent to the licensee. Locy v. Commonwealth of Pennsylvania, Liquor Control Board,
125 Pa. Commw. 481, 484, 557 A.2d 1164, 1165, allocatur denied, 522 Pa. 621, 563
A.2d 889 (1989). Rather, "[s]ending the notice by certified mail constitutes sufficient
compliance with the statute." Id. In this regard, the Commonwealth Court of
Pennsylvania has held that when notice is sent by certified mail and is returned
unclaimed, and a second notice is never receivedby the licensee, the "[r]emission of the
[original] notice by certified mail [was] sufficient compliance" with the provisions of
Section 4-471. Slovak American Citizens Club of Oakview v. Commonwealth of
Pennsylvania, Liquor Control Board, 120 Pa. Commw. 528, 536, 549 A.2d 251, 255
(1988). Furthermore, the Commonwealth Court has also held that, when a statute
requires mailing of notice by registered mail, "[n]otice of administrative action which
is mailed to the interested party's last known address has been found to be reasonable
notice." Kobylski v. Milk Marketing Board, 101 Pa. Commw. 155, 159, 516 A.2d 75,
77 (1986) (emphasis added).
In its brief, Appellant contends that "[d]elivery of the [notice letter] was not
made on the Licensee through no fault of the Licensee.... As between the LCE and the
Licensee, the Licensee is the innocent party and should not be made to bear the
12
358 CIVIL 1993
burden for the LCE's actions, oversights and choice of delivery service."' In so
contending, Appellant relies on the holding of the Commonwealth Court in Locy v.
Commonwealth o f Pennsylvania, Liquor Control Board, 116 Pa. Commw. 473, 542 A.2d
206 (1988). There, the Court held that notice sent via certified mail, which was
returned to the Board because of an incorrect zip code, was not sufficient to satisfy the
requirements of Section 4-471. The court noted that "[t]he intent of the legislature,
obviously, was that Licensee receive timely notice. The language used is
unambiguous." Id. at 475, 542 A.2d at 206. Therefore, since the Court could not"find
that the Board ha[d] complied with the notice requirement," it vacated the license
suspension. Id. at 475, 542 A.2d at 206-07.
In the present case, there was evidence adduced at the hearing to support the
finding that the Bureau of Liquor Control Enforcement complied with the notice
requirements of Section 4-471(b). As stipulated by counsel, the address on the letter
was the correct address for Appellant. Therefore, under the holdings of Slovak -
American Citizens Club and Kobylski, this constituted reasonable and sufficient notice.
Furthermore, unlike the situation of Locy, the failure of Appellant to receive the notice
sent via certified mail was not due to any error on the part of the Bureau of Liquor
Control Enforcement. Consequently, this Court is of the opinion that the actions of
the Bureau of Liquor Control Enforcement in sending the notice to Appellant were in
" Appellant's Brief at 13-14.
41
358 CIVIL 1993
sufficient compliance with Section 4-471(b).44
With respect to Appellant's contention that its license was impermissibly
revokedbecause "[n]o facts were presentedto sustain the finding that Appellant should
have known of such activity on the licensed premises,..41 it has been stated by the
Pennsylvania Supreme Court that "violations of criminal laws other than the Liquor
Code may constitute sufficient cause for revocation or suspension of a liquor license."
Commonwealth of Pennsylvania, Liquor Control Board v. TLK, Inc., 518 Pa. 500, 504,
544 A.2d 931, 933 (1988). However, if the misconduct relied upon to provide sufficient
cause is "by an employee or patron [and] is outside the liquor laws, a license is
revocable only if the licensee knew or should have known of the misconduct and if he
fails to prove that he took substantial affirmative measures to prevent the misconduct."
Id. at 505-06, 544 A.2d at 934.
In applying this standard to the case before it, the Court in TLK found that the
licensee was "deemed to have permitted or acquiesced in the misconduct," and,
therefore, affirmed the license revocation. Id. at 506, 544 A.2d at 934. In so holding,
the Court relied upon the testimony of an undercover narcotics agent indicating that
"he was able to purchase drugs from a patron of the establishment, and that he
44 This holding is further supported by the fact that Appellant should have become aware
of the violations and, thus, should have anticipated the Bureau's investigation of these
violations when the arrests occurred on the licensed premises on November 7, 1991.
45 Appellant's Appeal, paragraph 23.
10
358 CIVIL 1993
observed drug sales between patrons, sales of stolen goods, the use of drugs in the
bathroom, and a drug sale take place in the presence of the bartender." Id.
Consequently, the Court held, "[djue to the pervasive nature of this illicit activity, it
may be said that the licensee should have known of the misconduct of his employee."
Id.
In light of the holding of TLK, as well as the testimony given by Trooper
Stackhouse, this Court is of the opinion that there is substantial evidence in the record
to support the finding that Appellant should have known of the drug activities
occurring on the licensed premises. In addition to testifying as to her involvement in
at least thirty drug transactions, Trooper Stackhouse also testified as to her
observations of numerous instances of behavior leading one to believe that drug
activity was occurring on the premises. Such activities included frequent entering and
exiting of the restrooms,46 an unusual amount of phone calls made by the individuals
in Johnnie's Cafe 41 and the smoking of marijuana along the side of the building or
in the parking lot of the licensed premises.48 Furthermore, Trooper Stackhouse
testified that she observed Ronald P. Nott, the owner and president of Appellant, in
46 N.T. 117.
47 N.T. 118.
48 N.T. 118.
11
358 CIVIL 1993
the premises on a frequent baSis.49
Finery, Appellant contends that "[t]he decisions below failed to afford proper
weight to evidence presented that the Licensee took substantial affirmative action to
prevent illegal drug activity on the licensed premises after Licensee became aware of
the potential for such activity upon receiving the citation on February 15, 1992.i50
As such, Appellant contends, the "findings and conclusions of the PLCB [were]
arbitrary and capricious. 1151
As previously indicated, if it is determined that the licensee should have known
of the misconduct on the licensed premises, the burden then shifts to the licensee to
"prove the he took substantial affirmative measures to prevent the misconduct."
Commonwealth of Pennsylvania, Liquor Control Board u. TLK, Inc., 518 Pa. 500, 506,
544 A.2d 931, 933 (1988). In this regard, Appellant presented evidence before the
Administrative Law Judges that it had instituted preventative measures, including the
following: regular patrols of the bathrooms, 52 removal of individuals engaged in
illegal drug activity from the premises, 53 an anti-drug policy on the licensed
49 N.T. 161.
50 Appellant's Appeal, paragraph 25.
51 Appellant's Appeal, paragraph 26.
52 N.T. 207.
53 N.T. 244.
12
358 CIVIL 1993
premises, 54 an announcement of zero tolerance of drug activity on the licensed
premises, 55 and the termination of employees who are caught using or dealing
drugs." In considering these measures, the PLCB found that the "steps [taken by
Appellant] were not substantial affirmative measures inasmuch as they were limited
in their effect since the Licensee instituted these measures almost a year after the
investigation into the licensed premises began.i87
Our research has discovered no case law discussing those actions of a licensee
which would constitute affirmative measures to prevent misconduct occurring on his
or her premises.58 However, based upon the evidence presented at the hearing before
the Administrative Law Judges, and in light of the finding that Appellant should have
known that illegal drug activity was occurring on the licensed premises while no
remedial steps were taken, it cannot be said that the holding of the PLCB was
unsupported by substantial evidence. Nor can it be said that the PLCB committed an
error of law or abused its discretion in determining that Appellant failed, in a timely
u N.T. 247.
55 N.T. 210.
56 N.T. 211.
57 Opinion of the PLCB, at 6-7.
58 Appellant refers the court to a recent Commonwealth Court case which discusses the
innocent owner defense under the Controlled Substance Forfeiture Act. Commonwealth V.
502-504 Gordon Street, _ Pa. Commw. _, 607 A.2d 839 (1992). However, the holding of that
case was premised upon the specific language of the Act and, therefore, is not applicable to this
case.
13
358 CIVIL 1993
sense, to undertake affirmative measures to prevent the illegal drug activity from
occurring on the premises.
For these reasons, the following order will be entered:
ORDER OF COURT
AND NOW, thiEV9(day of July, 1993, upon careful consideration of Appellant's
Appeal from a liquor license suspension and fine imposed by the Pennsylvania Liquor
Control Board, as well as the briefs submitted upon the matter, and after review of the
record from the proceedings below, Appellant's Appeal is DISMISSED and the decision
of the Board is AFFIRMED.
Thomas M. Ballaron, Esq.
Attorney for Appellee
Stephen J. Dzuranin, Esq.
Attorney for Appellant
:rc
BY THE COURT,
J. Wesley OXler,
14