Com. v. Higginson, S.

CourtSuperior Court of Pennsylvania
DecidedSeptember 24, 2025
Docket2028 EDA 2024
StatusUnpublished

This text of Com. v. Higginson, S. (Com. v. Higginson, S.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Com. v. Higginson, S., (Pa. Ct. App. 2025).

Opinion

J-S30027-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : SAMANTHA NICO HIGGINSON : : Appellant : No. 2028 EDA 2024

Appeal from the Judgment of Sentence Entered July 16, 2024 In the Court of Common Pleas of Montgomery County Criminal Division at No(s): CP-46-SA-0000143-2024

BEFORE: OLSON, J., MURRAY, J., and FORD ELLIOTT, P.J.E. *

MEMORANDUM BY MURRAY, J.: FILED SEPTEMBER 24, 2025

Samantha Nico Higginson (Appellant) appeals from the judgment of

sentence imposed following her trial de novo and summary convictions of

traffic-control signals – steady red indication and driving while operating

privilege is suspended (driving under the influence (DUI) related). 1 After

careful review, we affirm.

The trial court summarized the relevant factual history as follows:

On March 23, 2023, Horsham Township Police Department Corporal Robert Johnson [(Corporal Johnson)] was in uniform [] in a marked patrol car when he observed a black Mercedes sedan … traveling south on Easton Road in Horsham Township, Montgomery County. At approximately 11:47 a.m. on March 23, 2023, Corporal Johnson observed the black Mercedes fail to stop ____________________________________________

* Retired Senior Judge assigned to the Superior Court.

1 75 Pa.C.S.A. §§ 3112(a)(3)(i), 1543(b)(1)(ii). Appellant’s red light violation is not at issue in the instant appeal. J-S30027-25

for a steady red light at the intersection of Easton Road and Maple Avenue. As a result, Corporal Johnson initiated a traffic stop on Easton Road near Columbia Avenue for a violation of the [M]otor [V]ehicle [C]ode. [] Corporal [Johnson] made contact with the operator of the black Mercedes, who[m] he later identified as Appellant. [C]orporal [Johnson] identified himself and requested Appellant’s driver’s license, registration, and insurance information. Appellant told Corporal Johnson that she did not have her driver’s license, and the sedan did not belong to her, so she did not know where the paperwork was located.

Corporal Johnson obtained Appellant’s name and date of birth and returned to his patrol car to check the status of Appellant’s driver’s license. The driver’s license query revealed that Appellant’s license was suspended, DUI related. The date of the traffic stop was within the suspension period.

As a result, Corporal Johnson issued a citation for failing to stop at a stead[y] red light and driving while operating privileges [are] suspended. [Corporal Johnson] testified that Appellant had told him her license had been restored, and he had responded that, if she brought the restoration letter from [the Pennsylvania Department of Transportation (PennDOT)] into the district court at the time of the hearing, he would withdraw the citation for driving under suspension.

Trial Court Opinion, 2/28/25, at 2-3 (citations and footnote omitted).

Pertinently, the driving under suspension citation charged Appellant

under 75 Pa.C.S.A. § 1543(a), which concerns license suspensions that are

not DUI related. See Defense Exhibit D-1 (Citation), 3/23/23. However,

under the section marked “Nature of Offense,” Corporal Johnson expressly

noted, “Operated vehicle with suspended license (DUI Related).” Id.

During the stop,

Corporal Johnson entered the citation into his computer system, but was unable to print the citation and hand Appellant a copy at the site of the traffic stop due to an issue with the patrol vehicle’s computer. Because the citation was filed in the computer system,

-2- J-S30027-25

it was automatically sent to district court. At the conclusion of the stop, Corporal Johnson advised Appellant that she would receive a copy of her citation in the mail.

Prior to the end of his shift on March 23, 2023, but after Corporal Johnson issued the citation, he returned to the police station and printed Appellant’s certified driving history from [PennDOT]. The certified driving history verifies the details of a license suspension. In addition, … officers [typically] send a certified driving history with citations for operating a vehicle under suspension so the[ district court] can determine the appropriate fine. Corporal Johnson placed Appellant’s certified driving history in the bin of citation documents to go to the district court…. Corporal Johnson described his understanding of the district court procedure as, once they receive the driving history, they enter the fine amount on the citation and then mail it to defendants with a hearing date.

Trial Court Opinion, 2/28/25, at 4-5 (citations omitted).

According to the trial court, the district court noted the discrepancy

between the section cited and the “Nature of Offense” description contained

in the citation:

Shortly after [Corporal Johnson] submitted the citation, he received an email from the district court clerk questioning the subsection listed on the citation because of the notation in the “Nature of [] Offense” box stating, “Operated vehicle with suspended license (DUI Related).” Corporal Johnson explained that the subsection should be 1543(b), not (a), because Appellant was driving under suspension, DUI related. The district court clerk asked [Corporal Johnson] to amend the citation to show the correct charge. At that time, Corporal Johnson was on night work[,] and the district court was closed during his shift. [Corporal Johnson] waited until he was back on day work, which was less than three weeks from the date of the traffic stop, to go to the court to amend the citation from 75 Pa.C.S.A. § 1543(a) to 75 Pa.C.S.A. § 1543(b)(1)(ii). Both Corporal Johnson and Magisterial District Justice Harry J. Nesbitt[,] III[,] initialed the amended notation on the citation. The district court clerk told Corporal Johnson that she would mail the amended citation to Appellant, as was the district court’s practice.

-3- J-S30027-25

Id. at 5-6 (citations omitted).

Following a summary trial on March 12, 2024, the district court found

Appellant guilty of the red light violation and driving while operating privileges

are suspended (DUI related). Appellant promptly filed a notice of appeal from

her summary convictions.

On April 16, 2024, Appellant filed a motion to dismiss the section

1543(b)(1)(ii) charge. Appellant argued the district court improperly directed

Corporal Johnson to appear in court, ex parte, to amend the citation. Motion

to Dismiss, 4/16/24, ¶ 5. Appellant also asserted Corporal Johnson was

required to verify the basis of the prior suspension before filing a citation. Id.,

¶¶ 6-7 (citing 75 Pa.C.S.A. § 1543(d)). Additionally, Appellant claimed she

was never served with the amended charge. Id., ¶¶ 11-12.

The trial court conducted a hearing on Appellant’s motion to dismiss on

May 16, 2024. During the hearing, Trooper Johnson explained why the

citation listed subsection 1543(a):

So at the time [of the traffic stop], my intention was to issue a citation for 1543(b). And this was the first time I was doing a 1543(b) electronically. All the previous times that I wrote the citation out where I … filled in the blocks on the written citation, I always put 1543(b), not (b)(1)(i); not (b)(1)(ii)[;] it was always (b). And [for] over 16 years, nobody ever mentioned to me about there is more to it than just (b). I was never corrected. I was never advised.

So when I went to do the electronic ticket, I was looking for 1543(b), and I put it in the box and (b) didn’t come up. It came up with, you know, like I said, (b)(1)(i), (b)(1)(ii). And I am thinking to myself, well, I don’t know what that is, and I didn’t

-4- J-S30027-25

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Cite This Page — Counsel Stack

Bluebook (online)
Com. v. Higginson, S., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-higginson-s-pasuperct-2025.