Commonwealth v. Hernandez

27 Pa. D. & C.3d 334, 1983 Pa. Dist. & Cnty. Dec. LEXIS 288
CourtPennsylvania Court of Common Pleas, Perry County
DecidedMarch 13, 1983
Docketno. 20 of 1983
StatusPublished

This text of 27 Pa. D. & C.3d 334 (Commonwealth v. Hernandez) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Perry County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Hernandez, 27 Pa. D. & C.3d 334, 1983 Pa. Dist. & Cnty. Dec. LEXIS 288 (Pa. Super. Ct. 1983).

Opinion

QUIGLEY, P.J.,

— On February 5, 1983, in Rye Township, Perry County, Pa., two automobiles collided on Route 850, causing the death of Kathy I. Kenee, operator of one of the vehicles. The other operator, Rigoberto Hernandez, defendant in this case, was charged by the Pennsylvania State Police with involuntary manslaughter (18 Pa.C.S. §2504), homicide by vehicle while under the influence (75 Pa.C.S.A. §3735(a) ), and driving under the influence of alcohol (75 Pa.C.S.A. §3731 (a)(1) & (4) ).

By pre-trial application, defendant has raised various issues which are now before us for decision. We are to understand that we have before us the first challenge to the constitutionality of what has become known as Pennsylvania’s “New Drunk Driving Law” in reality, amendments to the Motor Vehicle Code of 1977 (Act of June 17, 1976, P.L. 162 as amended).

Our decision in this case will not put to rest finally the substantial issues raised by the enactment of [336]*336this legislation, that being eventually the task of this state’s highest court.

A case such as this is difficult for most to understand. Many see a serious social problem* which the legislature has attempted to address by reasonable and overdue action, with attempts to challenge being viewed as arrogant or at least irrelevant. Others see the legislation as constituting a threat to civil liberties. It is always difficult to separate social issues from legal or constitutional issues.

The public awareness of the problem of driving under the influence, long overdue and laudable, is substantial. The attitudes of society can, do and should influence government. That influence is sometimes expressed in the enactment of legislation by a legislature responding to the will -of the people. In our democracy the will of the people expressed through legislation is limited only by the Constitutions of the United States and of this Commonwealth. The role of the courts in this context, simply stated, is to pass on the constitutionality of the legislative action before us.

CONSTITUTIONALITY OF MANDATORY SENTENCING PROVISION

A conviction under Section 3735(a) requires the imposition of a mandatory minimum sentence of three years, while a conviction under Section 3731 requires imprisonment of 48 hours for a first offense and up to a minimum of one year for the third or more offenses. A first offender may avoid the mandatory 48 hour sentence by electing, if he is eligible, to participate in an accelerated rehabilitative disposition program.

Defense contends that the mandatory sentencing provisions are unconstitutional because they violate the separation of powers doctrine, constitute cruel [337]*337and unusual punishment, violate due process, vest the prosecutor with unreviewable discretion, and in the case of first offenders under Section 3731 (which allows the ARD election), impose a penalty for exercising one’s right to a jury trial.

The legitimacy of the concept of legislatively directed mandatory sentences have been questioned before in the courts of this state and country and has uniformly withstood challenge on constitutional grounds.

On the equal protection issue

“. . .the legislature may distinquish the ills of society which require a criminal sanction, and may punish them appropriately, and thereby not violate constitutional limitations.” People v. Broadline, 37 New York 2d 100 (1975) annotated in 81 A.L.R. 2d 1192 at 1202.

The. fact that sentencing has become discretionary with the courts does not alter the fact that the judiciary’s authority to sentence comes from the legislature which always had the power to “. . .alter the penal regime 'even to a substantial degree. . .” State v. King, (1974 Me.) 330 A.2d 124, 81 A.L. R. 2d 1186. This case, speaking to the due process issue, is illustrative of the controlling proposition that appropriate mandatory sentencing rules do not violate due process.

It seems to us that a stiff mandatory sentence might at some point not be rationally related to a proper legislative purpose with the result that there might be sufficient disparity between the sentence and the harm to be avoided, so that the result might be deemed cruel. However, it seems clear that punishment is in the purview of the^ legislature, not the court.

[338]*338In summary, if legislative action design to address a social ill is reasonable it will not be held to violate any of the mentioned constitutional prohibitions.

While we are sure arguments will be made on the issue, we don’t see any infirmities in the mandatory sentencing provisions of this act. We view it as a reasonable, rational, appropraite legislative attempt to address a most serious social problem.

We do not see a constitutional problem in the issue of the prosecutor’s discretion. A district attorney, especially since the abolition of the grand jury, is vested with considerable discretion.- That discretion is ultimately reviewable at trial. A person charged is either guilty or not guilty. The risk that someone will be charged who should not be charged is not of serious concern because of the safeguard of a trial. The risk that someone will not be charged who should be charged is not greater or lesser now than it was before this Act.

It is true that to exact a penalty for the exercise of a right is an unconstitutional practice. Commonwealth v. Bethea, 475 Pa. Super. 571, 379 A.2d 102 (1977). And it is true that one may be tempted to opt for the security of AÍID rather than risk a sentence after electing a trial. However, if successful at trial, defendant goes away unfettered. His right to a trial is clear. He should think about the strength of his case and the Commonwealth’s case and the fact that he might well receive more than 48 hours before he decides whether or not to proceed to trial. He should think about whether he has a problem that a program (such as ARD) might be of help to him. While this issue is of concern, we think the section has a rational basis and is sustainable.

[339]*339PER SE .10 RULE

Section 3731(a)(4) permits a conviction if the driver’s blood alcohol content is . 10 or more without additional evidence. It is suggested by the defense that this provision is unconstitutionál because it violates due process, causes a shift or lightening of the burden of proof and it is vague and uncertain.

A “per se” rule is not novel. The Motor Vehicle Code for years has directed that no prosecution take place if blood alcohol content is less than .05. Other states have provisions similar to Pennsylvania’s new .10 per se rule and Pennsylvania for years provided that juries would be told that if. blood alcohol exceeded .10 there was a presumption of being under the influence. This presumption, of course, was not absolute.

Our research discloses uniform acceptance by other states of the constitutionality of such a provision. See State v. Hazma, (Fla.) 342 S.2d 80.

Of interest is that some states, under a similar statutory provision, permit a defendant to be convicted of both driving under the influence while impaired and driving with a . 10 blood alcohol content. Other states consider the one count to be lesser included in the other. See the cases annotated in 16. A.L.R. 3d 748 et seq.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Commonwealth v. Bethea
379 A.2d 102 (Supreme Court of Pennsylvania, 1977)
Commonwealth v. Clipper
449 A.2d 741 (Supreme Court of Pennsylvania, 1982)
State v. King
330 A.2d 124 (Supreme Judicial Court of Maine, 1974)
Sphaler v. Colman
379 So. 2d 717 (District Court of Appeal of Florida, 1980)

Cite This Page — Counsel Stack

Bluebook (online)
27 Pa. D. & C.3d 334, 1983 Pa. Dist. & Cnty. Dec. LEXIS 288, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-hernandez-pactcomplperry-1983.