A.H. Cromley v. Bureau of Driver Licensing

CourtCommonwealth Court of Pennsylvania
DecidedMarch 17, 2025
Docket456 C.D. 2023
StatusUnpublished

This text of A.H. Cromley v. Bureau of Driver Licensing (A.H. Cromley v. Bureau of Driver Licensing) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
A.H. Cromley v. Bureau of Driver Licensing, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Adam H. Cromley, : Appellant : : v. : : Commonwealth of Pennsylvania, : Department of Transportation, : No. 456 C.D. 2023 Bureau of Driver Licensing : Submitted: December 9, 2024

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge (P.) HONORABLE MARY HANNAH LEAVITT, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE FIZZANO CANNON FILED: March 17, 2025

Adam H. Cromley (Cromley) appeals from the April 12, 2023, opinion and October 10, 2023, order of the Court of Common Pleas of Northumberland County (trial court).1 The trial court’s order denied Cromley’s appeal of the lifetime disqualification of his commercial driver’s license (CDL) based on the Uniform Commercial Driver’s License Act (CDL Act), 75 Pa.C.S. §§ 1601-1622. Upon review, we vacate and remand to the trial court to issue a new opinion.

1 The trial court issued an April 12, 2023, opinion stating its disposition, which was docketed on April 13, 2013. However, the trial court did not issue a corresponding order at that time. Cromley timely appealed from the trial court’s opinion to this Court, which remanded in September 2023 for the trial court to formally issue an order, which it did on October 10, 2023. Reproduced Record (R.R.) at 104a. Accordingly, this opinion will use the trial court’s October 2023 order as the formal mechanism for this appeal. I. Factual & Procedural Background On June 13, 2022, the Department of Transportation’s Bureau of Driver Licensing (DOT) issued a notice advising Cromley that based on his refusal of chemical testing for suspicion of driving under the influence (DUI) on May 26, 2022, which was his second DUI-oriented offense, his CDL would be disqualified for life pursuant to Section 1611(c) of the CDL Act, 75 Pa.C.S. § 1611(c), which states that a combination of two or more enumerated offenses, including a DUI violation and/or a refusal of chemical testing for DUI, will result in lifetime CDL disqualification. Reproduced Record (R.R.) at 32a. In a timely appeal, Cromley asserted inter alia2 that lifetime CDL disqualification constituted cruel and unusual punishment pursuant to the Eighth Amendment to the United States Constitution and the corresponding provision of the Pennsylvania Constitution.3 The trial court held a hearing on February 28, 2023. R.R. at 1a-30a. Counsel for Cromley stipulated that in February 2006, Cromley committed a DUI offense that resulted in a one-year suspension of his CDL and that on May 26, 2022, he was stopped for a traffic violation and refused chemical testing for DUI. Id. at 8a-9a & 20a. Because Cromley stipulated to the May 2022 offense, the officer who conducted the stop did not testify to the particulars of the incident. Id. at 12a. However, the officer’s affidavit of probable cause in the original record, which was

2 Cromley raised additional challenges that were either resolved at the trial court level or are not at issue in this appeal.

3 The Eighth Amendment provides: “Excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted.” U.S. CONST. Amend. VIII. Article I, section 13 of the Pennsylvania Constitution provides: “Excessive bail shall not be required, nor excessive fines imposed, nor cruel punishments inflicted.” PA. CONST. Art. I, § 13. These provisions are treated as coextensive. Shoul v. Dep’t of Transp., Bureau of Driver Licensing, 173 A.3d 669, 682 n.13 (Pa. 2017).

2 admitted at the hearing, states that he observed Cromley fail to stop at an intersection with a flashing red light and fail to use his turn signal. In support of his Eighth Amendment claim, Cromley testified that he was 37 years old and worked previously as a maintenance mechanic earning about $30,000 per year. R.R. at 12a-14a. Once he got his CDL, his earnings increased to about $40,000 per year. Id. About three years ago, his brother, who had worked for their father, was killed in an airplane accident. Id. at 15a. Cromley started working for his father and earned about $120,000 his first year. Id. Since then, he earns about $80,000-$100,000 per year. Id. at 15a-16a. Cromley testified that he is married with no children; he and his wife’s monthly expenses (car payment, mortgage, utilities, gas, home heating oil, and car and home insurance) are about $3,000 per month. R.R. at 17a-18a. His wife is a teacher and earns about $45,000-$50,000 per year. Id. at 18a. He also helps his late brother’s son with some bills. Id. at 17a. He testified that if he loses his CDL, he would not be able to work for his father and would have to find some other kind of work, probably back as a mechanic earning about what he earned before getting his CDL. R.R. at 16a & 19a. It would be more physically difficult for him at his age and he and his wife would struggle to pay their bills. Id. at 19a. At the end of the hearing, the trial court ordered briefing from both sides. Id. at 26a. Cromley averred in his brief to the trial court that he had “presented more than sufficient information” and evidence to support his position that pursuant to the relevant law, lifetime disqualification of his CDL constituted cruel and unusual punishment. R.R. at 57a. He asserted that the May 2022 stop was for a minor traffic offense and not because he had been a specific harm to other drivers. Id. at 57a-58a. He referenced his hearing testimony that losing his CDL would have

3 a serious impact on his personal and professional life. Id. at 58a. He noted that even though he had a prior DUI from 2006, it was so long ago that his May 2022 refusal to submit to chemical testing for DUI was criminally charged as a first offense for which his punishment would be relatively minimal; his personal driver’s license might be suspended but would not be revoked for life. Id. In both offenses, he had been driving a personal vehicle, and no one was hurt. Id. He asserted that these factors rendered lifetime CDL disqualification grossly disproportionate punishment to his offenses. Id. at 59a. The DOT acknowledged in its brief to the trial court that lifetime CDL disqualification was penal in nature, as this Court held in Sondergaard v. Department of Transportation, Bureau of Driver Licensing, 65 A.3d 994 (Pa. Cmwlth. 2013). R.R. at 65a. The DOT applied the analytical framework set forth in Shoul v. Department of Transportation, Bureau of Driver Licensing, 173 A.3d 669 (Pa. 2017), which incorporated elements from Solem v. Helm, 463 U.S. 277 (1983), and Commonwealth v. 1997 Chevrolet and Contents Seized from Young, 160 A.3d 153 (Pa. 2017), to determine whether a particular punishment is grossly disproportionate to the offense. Id. at 66a-70a. The DOT asserted that under Solem, Section 1611(c) of the CDL Act did not violate the Eighth Amendment because the harshness of the penalty (lifetime CDL disqualification) corresponded with the gravity of the offense (multiple DUI- oriented offenses by a CDL holder). Id. at 70a-80a. The DOT referred to the CDL Act’s purpose of ensuring public health, safety, and welfare by disqualifying CDL holders who commit serious traffic violations and offenses, including DUIs. Id. at 71a (quoting Section 1602 of the CDL Act, 75 Pa.C.S. § 1602).

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Related

Solem v. Helm
463 U.S. 277 (Supreme Court, 1983)
United States v. Bajakajian
524 U.S. 321 (Supreme Court, 1998)
Orloff v. Commonwealth, Department of Transportation, Bureau of Driver Licensing
912 A.2d 918 (Commonwealth Court of Pennsylvania, 2006)
Commonwealth v. 1997 Chevrolet & Contents Seized From Young
160 A.3d 153 (Supreme Court of Pennsylvania, 2017)
Germantown Cab Co. v. Phila. Parking Auth.
206 A.3d 1030 (Supreme Court of Pennsylvania, 2019)
Sondergaard v. Commonwealth, Department of Transportation
65 A.3d 994 (Commonwealth Court of Pennsylvania, 2013)
Commonwealth v. Baker
78 A.3d 1044 (Supreme Court of Pennsylvania, 2013)

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Bluebook (online)
A.H. Cromley v. Bureau of Driver Licensing, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ah-cromley-v-bureau-of-driver-licensing-pacommwct-2025.