Com. v. Peralta, J.
311 A.3d 1
Pa. Super. Ct.2024Background
- Juan Evangalist Peralta was convicted of illegally operating a vehicle not equipped with an ignition interlock device in Pennsylvania and sentenced to 45 to 90 days of incarceration.
- The conviction arose after Peralta was stopped for driving a car with expired registration; his license indicated an ignition interlock requirement, but the vehicle lacked the device.
- Peralta’s driving record showed a prior suspension for refusal of chemical testing and restoration of his privileges in January 2020, requiring an ignition interlock for some period.
- The certified driving record did not clearly state if or when Peralta’s interlock restriction expired, generating uncertainty about his legal obligations.
- Peralta appealed, arguing the Commonwealth failed to prove that he was still required to use an ignition interlock because PennDOT did not provide the required statutory notice of ongoing obligation after the one-year period.
- The Superior Court held that statutory notice from PennDOT is a critical due process protection, and its absence is grounds for reversing the conviction under these facts.
Issues
| Issue | Peralta's Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for interlock offense | Commonwealth did not prove he had notice of his ongoing interlock obligation as required by statute | Ignorance of the law is no excuse; statute puts Peralta on notice, and possession of an IILL shows knowledge | Reversed: Commonwealth had to show PennDOT provided statutory notice of ongoing obligation |
| Weight and sufficiency of evidence for summary offenses | Peralta abandoned these challenges on appeal | Not addressed | Not addressed (affirmed below) |
Key Cases Cited
- Commonwealth v. Kane, 333 A.2d 925 (Pa. 1975) (Commonwealth must prove actual notice of suspension to convict for driving under suspension)
- Commonwealth v. Crockford, 660 A.2d 1326 (Pa. Super. 1995) (notice is a judicially created element for due process in suspension cases)
- Commonwealth v. Thomas, 988 A.2d 669 (Pa. Super. 2009) (standard of review for sufficiency of evidence)
- Commonwealth v. Samuels, 778 A.2d 638 (Pa. 2001) (strict liability for public welfare offenses)
- Commonwealth v. Collins, 810 A.2d 698 (Pa. Super. 2002) (strict liability for DUI)