Commonwealth v. Montross

28 Pa. D. & C.2d 781, 1962 Pa. Dist. & Cnty. Dec. LEXIS 72
CourtWyoming County Court of Quarter Sessions
DecidedAugust 8, 1962
Docketnos. 18 and 19
StatusPublished

This text of 28 Pa. D. & C.2d 781 (Commonwealth v. Montross) is published on Counsel Stack Legal Research, covering Wyoming County Court of Quarter Sessions primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Montross, 28 Pa. D. & C.2d 781, 1962 Pa. Dist. & Cnty. Dec. LEXIS 72 (Pa. Super. Ct. 1962).

Opinion

Trembath, P. J.,

These matters come before the court on waived hearings under section 1205 (b) of The Vehicle Code of April 29, 1959, P. L. 58. In each ease informations were lodged with the justice of the peace charging each defendant with reckless driving in Tunkhannock Borough, on March 23. 1962.

[782]*782It was stipulated that defendants’ exhibits one and two are identical and are the letters mailed April 10, 1962, by the justice of the peace to defendants. Each of the letters reads as follows:

“Dear Sir:—
Enclosed find a copy of an information filed with me of a Violation by you of the Motor Vehicle Code. The fine and costs are $15.00. If you wish, you may send it to me and you will not have to appear; but if you wish a hearing, I will hear you at my office, No. 14% East Tioga Street, Tunkhannock, Pa., on the 20th day of April, 1962, at 1:00 o’clock P.M.
If you desire a hearing please notify me in advance, so that you may be spared the inconvenience of continuances.
Awaiting your pleasure, I remain
Yours truly,
Cecil Krewson, Jr.
J.P.
My Commission expires first Monday in Jan. 1966”
(Seal)

In each case the attorney for defendants moved to quash the proceedings and dismiss defendants, (1) because the justice’s transcript shows that each defendant was not given the statutory notice to appear, and (2) that the notices that were in fact given, did not conform to the statutory requirements, and that therefore the justice of the peace did not acquire jurisdiction over the person of the defendants.

We are unable to reconcile our views with those of many lower courts when differentiating the procedural steps necessary to vest jurisdiction over the subject matter of a motor vehicle violation, from the procedural steps which perfect jurisdiction over the person of the defendant.

[783]*783The Vehicle Code attaches jurisdiction over the subject matter in any motor vehicle violation in the justice of the peace who happens to be the nearest available justice in the municipality where the violation occurred. The only procedural step, as we view it, which is necessary to vest that jurisdiction, is that the jurisdiction be invoked by a sworn information lodged with that justice. This jurisdictional step is complicated when the nearest justice is not available, or when no justice is available in the municipality where the violation occurred, and sometimes by the fact that a single violation occurred while defendant was traveling in different municipalities. Nevertheless the procedural step remains the same, and the complications are resolved by evidence. It is our view that only when the correctness of the choice of the justice of the peace is attacked on the ground that he was not the nearest available justice of the peace, or that he was not a justice of the peace in the municipality where the offense took place, or something similar, is there an attack upon the justice’s jurisdiction of the subject matter. This also is the view of Judge McDade in Commonwealth v. Walter, 39 D. & C. 383, 388: “We are of the opinion that, . . . the magistrate’s jurisdiction of the subject matter attaches upon the filing of the information ..

As we view it, all other procedural steps are taken in these cases to establish the justice’s jurisdiction over the person of the defendant. In this latter group would be included the letter sent by the justice of the peace to defendant giving defendant ten days in which to appear, which is the procedural step here under attack.

There has never been any doubt that when a justice of the peace had no jurisdiction over the subject matter, all proceedings before him are fatally defective, and nothing defendant did or failed to do could remedy this defect, and the matter could be raised at any time, before or after his appearance, before or after judg[784]*784ment, and this defect can be raised for the first time in the appellate courts: Commonwealth v. Gill, 166 Pa. Superior Ct. 223, 227; Commonwealth et rel. Paylor v. Cavell, 185 Pa. Superior Ct. 176, 185.

It is in those cases where defendant in a motor vehicle violation has waived hearing and given bond for appearance “for trial before a Judge of the Court of Quarter Sessions” and then attacks, as defective, some procedural step before the justice of the peace that confusion exists in the decisions of the lower courts. Some courts have held that defendant’s appearance and waiver of hearing before the justice of the peace is a waiver of any procedural error going to jurisdiction over the person: Commonwealth v. Maun, 68 D. & C. 288, 292; Commonwealth v. Wentz, 52 D. & C. 690; Commonwealth v. Greene, 40 D. & C. 546; Commonwealth v. Moore, 15 D. & C. 263.

On the other hand other courts have held that the waiving of hearing before the justice of the peace and giving bond for appearance before the quarter sessions court is not a waiver of procedural defects going to jurisdiction over the person, and that defective procedural steps are fatal to the proceeding and will be so declared by the court of quarter sessions: Commonwealth v. Hastings, 14 D. & C. 811; Commonwealth v. Nottage, 11 D. & C. 719; Commonwealth v. Myers, 22 D. & C. 586, 589; Commonwealth v. Walter, 39 D. & C. 383, 390; Commonwealth v. Arnold, 86 D. & C. 154; Commonwealth v. Beaver, 58 D. & C. 97.

The appellate courts have not resolved the difficulty. Commonwealth v. Burall, 146 Pa. Superior Ct. 525, involves a case where the attack was on the jurisdiction over the subject matter, for in that case defendant alleged that the record failed to show that the justice of the peace was the nearest available. The ruling in that case cannot, and does not throw light on the controversy over the effect of error in procedural steps undertaken [785]*785to effect jurisdiction over the person of the defendant. Similarly in Commonwealth v. Gill, 166 Pa. Superior Ct. 223, the issue went to jurisdiction over the subject matter since defendant’s point was that the magistrate in municipality (a) could not have jurisdiction since the offense happened in municipality, (b) and that one or more justices of the peace had been commissioned in the latter municipality.

The Superior Court in Commonwealth v. Meckes, 144 Pa. Superior Ct. 381, held that the court of quarter sessions had no right to issue a writ of certiorari to a magistrate or justice of the peace. The court said at page 382:

“This is determined by article 5 §10, of the Constitution of Pennsylvania... which reads as follows: ‘The judges of the courts of common pleas, within their respective counties, shall have power to issue writs of certiorari to justices of the peace and other inferior courts not of record, and to cause their proceedings to be brought before them, and right and justice to be done’. This section is the only constitutional authority existing in this state for issuing such writs of certiorari, excepting that possessed by the Supreme Court under article 5 §3, of the Constitution ...

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Bluebook (online)
28 Pa. D. & C.2d 781, 1962 Pa. Dist. & Cnty. Dec. LEXIS 72, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-montross-paqtrsesswyomin-1962.