Sule v. Philadelphia Parking Authority, 26 A.3d 1240

Sule, a certified taxicab driver, was cited by the Philadelphia Parking Authority for inhibiting a passenger's use of a credit card, under Executive Order 07-0002 as reclassified by Board Order 08-0005.
Hedrick, the passenger, paid with a credit card and later complained the driver tried to force cash payment; her written statement was introduced into evidence after the hearing.
Inspector Rotan conducted the investigation, testified about Hedrick's statements and Hedrick's written statement, and concluded Sule inhibited Hedrick's use of a credit card.
The Hearing Officer admitted Hedrick's statement and Rotan's account, crediting them to find a violation and imposing a $500 fine under Board Order 08-0005.
Sule testified he accepted Hedrick's card and explained the card reader location and transaction mechanics; he denied any intent to inhibit payment.
This Court reviews the agency adjudication for substantial evidence and any constitutional or legal defects in procedures.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether hearsay evidence alone supports the judgment	Sule	Sule	Reversed; hearsay not corroborated voids finding
Validity and enforceability of Executive Order 07-0002 and Board Order 08-0005	Sule	Sule	Not reached; but there is doubt about enforceability

Chapman v. Unemployment Compensation Board of Review, 20 A.3d 603 (Pa.Cmwlth.2011) (hearsay may be used if corroborated)
Walker v. Unemployment Compensation Board of Review, 367 A.2d 366 (Pa.Cmwlth.1976) (Walker rule: corroboration required when hearsay is admitted without objection)
J.K. v. Department of Public Welfare, 721 A.2d 1127 (Pa.Cmwlth.1998) (hearsay cannot corroborate hearsay)
Germantown Cab Co. v. Philadelphia Parking Authority, 993 A.2d 933 (Pa.Cmwlth.2010) (Commonwealth Documents Law compliance; orders vs regulations)
Tarner v. Bitner, 294 Pa. 549 (1929) (limits on regulatory actions via orders for industry-wide impact)