Ferguson, H., Aplt. v. Dept. of Transportation

CourtSupreme Court of Pennsylvania
DecidedJuly 22, 2025
Docket73 MAP 2022
StatusPublished

This text of Ferguson, H., Aplt. v. Dept. of Transportation (Ferguson, H., Aplt. v. Dept. of Transportation) is published on Counsel Stack Legal Research, covering Supreme Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ferguson, H., Aplt. v. Dept. of Transportation, (Pa. 2025).

Opinion

[J-85-2024] IN THE SUPREME COURT OF PENNSYLVANIA MIDDLE DISTRICT

TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.

HENRY EARL FERGUSON, : No. 73 MAP 2022 : Appellant : Appeal from the Order of the : Commonwealth Court dated : December 22, 2021 at No. 123 CD v. : 2021 Affirming the Order of the : Cumberland County Court of : Common Pleas, Civil Division, dated COMMONWEALTH OF PENNSYLVANIA, : January 21, 2021 at No. 2020-4835 DEPARTMENT OF TRANSPORTATION, : CV. BUREAU OF DRIVER LICENSING, : : ARGUED: November 19, 2024 Appellee :

OPINION

JUSTICE MUNDY DECIDED: July 22, 2025 The issue presented in this appeal by allowance is whether, consistent with due

process, a driver who resolved an earlier DUI charge via accelerated rehabilitative

disposition (ARD) may have his privileges suspended based on a subsequent DUI

conviction.

In 2012, Appellant was charged with driving under the influence (DUI), see 75

Pa.C.S. § 3802, and he successfully resolved that charge through ARD acceptance. 1 In

2020, Appellant was again charged with DUI, specifically, DUI-general impairment as an

1 ARD acceptance is discussed below. Briefly, when a driver is charged with DUI under Section 3802 as a first offense in ten years, the prosecutor, subject to certain exceptions, may offer the driver the opportunity to resolve those charges through ARD, a diversionary program that does not result in a criminal conviction and is largely rehabilitative in nature. ungraded misdemeanor under 75 Pa.C.S. §3802(a)(1). He was convicted based on his

guilty plea. PennDOT received notice of his conviction and suspended his license for one

year pursuant to Section 3804(e) of the Vehicle Code, which provides in relevant part:

(e) Suspension of operating privileges upon conviction.--

(1) The department shall suspend the operating privilege of an individual under paragraph (2) upon receiving a certified record of the individual's conviction of or an adjudication of delinquency for: (i) an offense under section 3802 . . ..

(2) Suspension under paragraph (1) shall be in accordance with the following: (i) Except as provided for in subparagraph (iii), 12 months for an ungraded misdemeanor or misdemeanor of the second degree under this chapter. (ii) 18 months for a misdemeanor of the first degree or felony of the third degree under this chapter. (iii) There shall be no suspension for an ungraded misdemeanor under section 3802(a) where the person is subject to the penalties provided in subsection (a) and the person has no prior offense. 75 Pa.C.S. § 3804(e) (emphasis added).

As can be seen, the above provision requires a one-year suspension unless the

present conviction is for an ungraded misdemeanor under section 3802(a) where the

person, inter alia, has no prior offense. 2 As for what constitutes a “prior offense,” the

Vehicle Code defines the term to include, inter alia, prior convictions and juvenile

adjudications, and, most relevant to this matter, “acceptance of Accelerated Rehabilitative

Disposition” to resolve a DUI charge lodged per Section 3802 within ten years before the

date of the current offense. See id. §3806. Thus, under the statute Appellant’s 2012

ARD acceptance qualifies as a “prior offense” for purposes of his license suspension

stemming from his 2020 conviction.

2 The other requirement is that the driver is subject to the penalties in subsection (a). In the instant case, there is no dispute that Appellant satisfies that prerequisite.

[J-85-2024] - 2 Appellant appealed his license suspension to the county court, which upheld it

notwithstanding that the Superior Court’s ruling in Commonwealth v. Chichkin, 232 A.3d

959 (Pa. Super. 2020), was still in force. Chichkin disapproved of enhanced criminal

sentencing based on an earlier ARD in light of Alleyne v. United States, 570 U.S. 99, 103

(2013), which held that any fact that increases the mandatory minimum sentence for a

crime must be submitted to a jury and proved beyond a reasonable doubt. 3 The county

court in the present matter reasoned that the Alleyne principle does not apply to a license

suspension which, as a civil penalty, “does not implicate the rigorous constitutional

safeguards applicable in criminal matters.” Ferguson v. PennDOT, 2021 WL 908562, at

*2 (C.P. Cumberland Jan. 21, 2021).

The Commonwealth Court affirmed in a published decision. See Ferguson v.

PennDOT, 267 A.3d 628 (Pa. Cmwlth. 2021). That tribunal agreed with the county court

that a license suspension is a civil, collateral consequence of a DUI conviction. As such,

the Commonwealth Court reasoned, it should be upheld so long as PennDOT produces

an official record of the conviction and demonstrates it acted in accordance with

applicable law. Therefore, the court continued, Appellant could only prevail if he could

demonstrate the record of his conviction was inaccurate – something he failed to do. See

id. at 633 (quoting Spagnoletti v. PennDOT, 90 A.3d 759, 766 (Pa. Cmwlth. 2013)).

We granted further review to consider whether Appellant’s license suspension in

these circumstances violates due process inasmuch as his successful completion of the

ARD program in relation to the prior charge was not a criminal conviction. See Ferguson

v. PennDOT, 280 A.3d 859 (Pa. 2022) (per curiam).

3 After the events underlying this appeal, Chichkin was overruled by Commonwealth v.

Moroz, 284 A.3d 227 (Pa. Super. 2022) (en banc), and Commonwealth v. Richards, 284 A.3d 214 (Pa. Super. 2022) (en banc). The substantive holdings of those decisions, in turn, were recently overturned by this Court in Commonwealth v. Shifflett, 335 A.3d 1158 (Pa. 2025).

[J-85-2024] - 3 Appellant primarily advances that drivers have a constitutionally-protected

property interest in retaining their driving privileges, meaning any deprivation of that

privilege cannot occur absent due process, including fundamental fairness. In PennDOT

v. Middaugh, 244 A.3d 426 (Pa. 2021), he notes, this Court held a DUI-based license

suspension was fundamentally unfair, thereby violating substantive due process, where

PennDOT waited 28 months to notify the driver, and the delay resulted in prejudice to the

driver. See id. at 438-39. Appellant posits it is likewise fundamentally unfair for a statute

to equate a prior ARD with a prior conviction and accordingly to require a license

suspension. He states the unfairness arises from the Vehicle Code allegedly treating an

ARD participant as a recidivist where ARD requires no finding of guilt.

It is true that, if a driver successfully completes ARD, he can obtain a dismissal of

charges, see Pa.R.Crim.P. 319, and an expungement of his arrest record, see

Pa.R.Crim.P. 320. 4 Because ARD acceptance does not entail proof of guilt, the

intermediate courts have held, for example, that successful ARD completion to resolve a

charge of theft, standing alone, is not sufficient evidence of willful misconduct to deny

unemployment compensation, see Reading Area Water Auth. v. UCBR, 137 A.3d 658,

663-64 (Pa. Cmwlth. 2016), nor is it equivalent to a crimen falsi conviction for purposes

of impeaching a witness, see Commonwealth v. Brown, 673 A.2d 975, 979 (Pa. Super.

1996). But cf., e.g., DeNillo v. Denillo, 535 A.2d 200, 202 (Pa. Super. 1987) (finding a

parent’s ARD resolution as to a charge involving sexual misconduct relevant in a custody

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