K. Eckenrode v. PennDOT, Bureau of Driver Licensing
168 C.D. 2015
Pa. Commw. Ct.Jul 14, 2016Background
- In 2005 Eckenrode was convicted in York County under the Drug Act for possession with intent to deliver.
- The York County Clerk of Courts did not transmit the certified conviction record to PennDOT until September 17, 2014.
- PennDOT mailed Eckenrode notice of a six-month license suspension under 75 Pa. C.S. §1532(c) on September 25, 2014; suspension effective October 30, 2014.
- Eckenrode conceded the conviction but testified he reformed (married, children, two jobs, real-estate license) and would suffer hardship if his license were suspended.
- The trial court sustained Eckenrode’s challenge, citing laches and undue hardship; PennDOT appealed.
- This Court affirmed the trial court but based its decision on the Gingrich extraordinary-circumstances exception rather than laches.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an administrative suspension may be invalidated where reporting delay was caused by clerk of courts, not PennDOT | Delay of nine years is prejudicial; enforcement now would cause undue hardship and is inequitable | PennDOT acted promptly after receiving the report and thus suspension is valid under precedent | Where delay is extraordinarily long, licensee has long clean record, and prejudice is shown, suspension may be vacated (Gingrich exception applies) |
| Whether laches/estoppel can bar PennDOT's suspension | Laches should bar enforcement due to long delay and resulting reliance/prejudice | Laches inapplicable because PennDOT exercised due diligence once it received the report | Laches inapplicable here because delay was attributable to clerk of courts; PennDOT responded within eight days |
Key Cases Cited
- Department of Transportation, Bureau of Driver Licensing v. Green, 546 A.2d 767 (Pa. Cmwlth. 1988) (delay by clerk of courts generally does not invalidate DOT suspensions)
- Pokoy v. Department of Transportation, Bureau of Driver Licensing, 714 A.2d 1162 (Pa. Cmwlth. 1998) (two-prong test: DOT-attributable unreasonable delay plus reliance/prejudice required to overturn suspension)
- Fordham v. Department of Transportation, Bureau of Driver Licensing, 663 A.2d 868 (Pa. Cmwlth. 1995) (relevant delay period is between DOT receipt of conviction and DOT notice to driver)
- Gingrich v. Department of Transportation, Bureau of Driver Licensing, 134 A.3d 528 (Pa. Cmwlth. 2016) (recognized narrow exception: extraordinarily extended reporting delay, long clean record, and demonstrated prejudice can warrant vacatur)
- Reform Congregation Oheb Sholom v. Berks County Bd. of Assessment Appeals, 839 A.2d 1217 (Pa. Cmwlth. 2004) (elements of estoppel by laches require delay by complaining party and prejudice to the asserting party)