Meter v. Commonwealth, Department of Transportation, Bureau of Driver Licensing
41 A.3d 901
| Pa. Commw. Ct. | 2012Background
- Meter’s license recall for medical incompetence under 75 Pa.C.S. §§ 1519(a),(c) following a July 25, 2010 fatal crash and a medical report by a physician’s assistant.
- Department recalled driving privilege based on a medical report indicating alcohol/substance abuse affecting safe operation.
- Meter appealed the recall to the trial court, which granted supersedeas and held a de novo hearing.
- Evidence included the medical report, the Recall Notice, and Meter’s driving record; Meter produced his mother as sole rebuttal witness.
- Trial court found the Department failed to prove medical incompetence; Department appealed to Commonwealth Court.
- Commonwealth Court reversed the trial court and reinstated the license recall, holding evidence supported medical incompetence and that driving history could be relevant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rebuttal burden: did mother’s testimony rebut the prima facie medical incompetence? | Meter argues mother’s testimony suffices to rebut the prima facie case. | Department contends mother’s testimony is competent but insufficient to rebut medical evidence. | Meter did not rebut; mother’s testimony insufficient. |
| Relevance of driving history to medical incompetence | Meter argues driving record is irrelevant to medical condition. | Department argues driving record can be probative of alcohol/substance use. | Driving history can be relevant to infer alcohol/substance use. |
| Compliance with §1519(a) procedure (initial report vs. provider report) | Meter claims PennDOT violated §1519(a) by not letting him submit a second medical report. | Department maintains initial report sufficed to establish prima facie and recall. | PennDOT’s use of initial report established prima facie; procedural defect not required to submit additional report. |
| Sufficiency of evidence to establish medical incompetence | Meter argues the medical report lacks detailed diagnosis and driver impact. | Department contends medical report plus driving record show incompetence. | Medical report plus record constitute prima facie evidence of incompetence. |
Key Cases Cited
- Byler v. Department of Transportation, Bureau of Driver Licensing, 883 A.2d 724 (Pa. Cmwlth. 2005) (lay testimony can rebut medical evidence of incompetence when details are lacking)
- Ploof v. Commonwealth of Pennsylvania, 139 Pa.Cmwlth. 235 (Pa.Cmwlth. 1991) (medical report suffices to establish prima facie case)
- Reynolds v. Department of Transportation, Bureau of Driver Licensing, 694 A.2d 361 (Pa.Cmwlth. 1997) (medical report can establish prima facie case; burden then shifts)