Commonwealth v. Langley
145 A.3d 757
| Pa. Super. Ct. | 2016Background
- On Nov. 14, 2013 Langley was investigated after a motor-vehicle accident; officers detected alcohol and he failed field sobriety tests. His BAC was .092%.
- Langley was charged with two DUI counts (75 Pa.C.S. §3802(a)(1) and (a)(2)) and failing to drive at a safe speed (75 Pa.C.S. §3361); Count 1 alleged exposure to the mandatory-minimum enhancement in 75 Pa.C.S. §3804(b)(2) (accident causing injury or property damage) and noted two other §3804 provisions were not applicable.
- Langley filed an omnibus pretrial motion to quash Count 1 and demanded a jury trial; the trial court denied the motion.
- After a bench trial the court convicted Langley of DUI (incapable of safely driving) and unsafe speed and sentenced him to 30 days to 6 months’ incarceration.
- On appeal Langley argued (1) the information improperly included sentencing/penalty language beyond the elements in violation of Pa.R.Crim.P. 560, and (2) Article I, §9 (and §6) of the Pennsylvania Constitution guarantees a jury trial for this DUI.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Count 1 should be quashed for including sentencing/penalty language beyond the elements (Rule 560) | Commonwealth: inclusion of accident/lifting language was proper because those facts are elements that trigger a mandatory minimum under §3804(b) and thus must be alleged | Langley: information contained superfluous sentencing language and facts not elements, violating Rule 560 | Court: Denied quash — Alleyne/Hopkins require allegation of facts that trigger mandatory minima; Commonwealth satisfied Rule 560 |
| Whether Article I, §9 (and §6) of PA Constitution guarantees a jury trial for this DUI (an ungraded misdemeanor with max ≤6 months) | Commonwealth: no absolute state constitutional right to jury trial for petty offenses; legislature classified the offense as petty by setting max ≤6 months | Langley: DUI should be treated as "serious" because first DUI affects future penalties; PA Constitution's term "inviolate" gives broader protection than federal counterpart | Court: Denied — Pennsylvania follows the petty/serious dividing line (Mayberry/Blanton); DUI with max ≤6 months is a petty offense and no jury right; Kerry controls |
Key Cases Cited
- Commonwealth v. Hopkins, 117 A.3d 247 (Pa. 2015) (facts that trigger mandatory minimums are elements that must be charged and proven beyond a reasonable doubt)
- Alleyne v. United States, 133 S. Ct. 2152 (U.S. 2013) (any fact increasing mandatory minimum is an element for jury to decide)
- Commonwealth v. Mayberry, 327 A.2d 86 (Pa. 1974) (right to jury trial guaranteed only for "serious" offenses carrying more than six months’ imprisonment)
- Commonwealth v. Kerry, 906 A.2d 1237 (Pa. Super. 2006) (applying Mayberry/Blanton to DUI: first-time DUI with max ≤6 months is a petty offense no jury right)
- Blanton v. North Las Vegas, 489 U.S. 538 (U.S. 1989) (identifies six-month maximum as the principal objective indicator separating petty from serious offenses)
- Commonwealth v. Watley, 81 A.3d 108 (Pa. Super. 2013) (discussing Alleyne’s impact on Pennsylvania mandatory minimum statutes)